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                              September 7, 2023

       Huiling Ying
       Chief Executive Officer
       ChinaCache International Holdings Ltd.
       No 8 Zhuyuan 3rd Street, Area 3
       Tianzhu Comprehensive Bonded Zone
       Shunyi District, Beijing, China

                                                        Re: ChinaCache
International Holdings Ltd.
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            File No. 001-34873

       Dear Huiling Ying:

              We have limited our review of your filing to the submission
and/or disclosures as
       required by Item 16I of Form 20-F and have the following comments. In
some of our comments,
       we may ask you to provide us with information so we may better
understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 20-F for the Fiscal Year Ended December 31, 2022

       Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 135

   1.                                                   We note your statement
that you reviewed your register of members and the public filings
                                                        made by your
shareholders in connection with your required submission under paragraph
                                                        (a). Please
supplementally describe any additional materials that were reviewed and tell us
                                                        whether you relied upon
any legal opinions or third party certifications such as affidavits
                                                        as the basis for your
submission. In your response, please provide a similarly detailed
                                                        discussion of the
materials reviewed and legal opinions or third party certifications relied
                                                        upon in connection with
the required disclosures under paragraphs (b)(2) and (3).
 Huiling Ying
FirstName
ChinaCacheLastNameHuiling    Ying Ltd.
            International Holdings
Comapany 7,
September  NameChinaCache
             2023            International Holdings Ltd.
September
Page 2    7, 2023 Page 2
FirstName LastName
2.       In order to clarify the scope of your review, please supplementally
describe the steps you
         have taken to confirm that none of the members of your board or the
boards of your
         consolidated foreign operating entities are officials of the Chinese
Communist Party. For
         instance, please tell us how the board members    current or prior
memberships on, or
         affiliations with, committees of the Chinese Communist Party factored
into your
         determination. In addition, please tell us whether you have relied
upon third party
         certifications such as affidavits as the basis for your disclosure.
3.       We note that your disclosures pursuant to Items 16I(b)(2), (b)(3), and
(b)(5) are provided
         for    ChinaCache International Holdings Ltd. or the VIEs.    We also
note that your list of
         subsidiaries in Exhibit 8.1 appears to indicate that you have
subsidiaries in Hong Kong
         and countries outside China that are not included in your VIEs. Please
note that Item
         16I(b) requires that you provide disclosures for yourself and your
consolidated foreign
         operating entities, including variable interest entities or similar
structures.
             With respect to (b)(2), please supplementally clarify the
jurisdictions in which your
              consolidated foreign operating entities are organized or
incorporated and provide the
              percentage of your shares or the shares of your consolidated
operating entities owned
              by governmental entities in each foreign jurisdiction in which
you have consolidated
              operating entities in your supplemental response.
             With respect to (b)(3) and (b)(5), please provide the required
information for you and
              all of your consolidated foreign operating entities in your
supplemental response.
4.       With respect to your disclosure pursuant to Item 16I(b)(5), we note
that you have included
         language that such disclosure is    to our knowledge.    Please
supplementally
         confirm without qualification, if true, that your articles and the
articles of your
         consolidated foreign operating entities do not contain wording from
any charter of the
         Chinese Communist Party.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact Kyle Wiley at (202) 344-5791 or Andrew Mew at (202)
551-3377 with
any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Disclosure Review
Program
cc:      Lawrence Venick