November 21, 2019

Vincent Jiang
Chief Financial Officer
Cheetah Mobile Inc.
Building No. 8
Hui Tong Times Square
Yaojiayuan South Road
Beijing 100123
People's Republic of China


       Re: Cheetah Mobile Inc.
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Filed April 26, 2019
           File No. 001-36427

Dear Mr. Jiang:

       We have reviewed your filing 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. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

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

Form 20-F for the Fiscal Year Ended December 31, 2018

Item 5. Operating and Financial Review and Prospects
A. Operating Results
Year Ended December 31, 2018 Compared to Year Ended December 31, 2017, page 101

1.    We note that revenues from utility products and related services have
significantly
      declined since 2016 and declines continue into 2019. Please expand your
disclosure,
      qualitatively and quantitatively, to address the major factors that
contributed to the
      contraction in your utility products business, including but not limited
to the loss of
      customers, the suspension or removal of certain popular apps as a result
of certain third
      party allegations, and softening of advertising demand. Also, please
disclose whether you
 Vincent Jiang
Cheetah Mobile Inc.
November 21, 2019
Page 2
         expect these trends will continue to impact your results of
operations. As part of your
         response, please tell us what consideration was given to separately
disclosing the
         advertising revenues included in utility products and related services
and mobile
         entertainment revenue to provide more visibility to investors into
advertising revenue
         trends. Please refer to Section III.D of SEC Release 33-6835 and
Section III.B. of SEC
         Release 33-8350.
Critical Accounting Policies
Goodwill, page 108

2.       Please tell us how you considered the qualitative factors outlined in
ASC 350-20-35-3C
         when performing your goodwill impairment analysis and clarify whether
you performed a
         qualitative or quantitative assessment, or both. Please tell us the
percentage by which the
         fair value exceeded the carrying value for your reporting units. To
the extent any
         reporting unit is at risk of failing step one of the goodwill
impairment test, please disclose
         the percentage by which the fair value exceeded the carrying value as
of the date of the
         most recent test and describe any potential events and/or changes in
circumstances that
         could reasonably be expected to negatively affect any key assumptions.
If you have
         determined that the estimated fair value substantially exceeds the
carrying value of your
         reporting units, please disclose such determination. Refer to Section
V of SEC Release
         33-8350.
Consolidated Financial Statements
Consolidated Statements of Comprehensive Income, page F-6

3.       We note that the utility products and related services line item
includes anti-virus and
         office application software. Please tell us what consideration was
given to separately
         disclosing product revenue from service revenue. Refer to Rule
5-03(b)(1) of Regulation
         S-X.
Notes to the Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue recognition
Other utility products related services, page F-29

4.     Please explain your basis for recognizing revenue from term-based
licenses ratably over
FirstName LastNameVincent Jiang
       time and refer to the authoritative guidance that supports your
accounting. As part of your
Comapany NameCheetah Mobile Inc.
       response, please quantity the revenue recognized from these arrangements
in the periods
       presented.
November 21, 2019 Page 2
FirstName LastName
 Vincent Jiang
FirstName LastNameVincent Jiang
Cheetah Mobile Inc.
Comapany 21, 2019
November NameCheetah Mobile Inc.
Page 3
November 21, 2019 Page 3
FirstName LastName
Mobile games, page F-29

5.       Please expand your disclosure to describe the nature of the in-game
virtual items and your
         performance obligations to the paying players. As part of your
response, explain to
         us why this revenue is recognized ratably over the average paying
players life.
         Additionally, revise to disclose how you determine the estimated
average paying player's
         life.
        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.

        You may contact Kathryn Jacobson, Senior Staff Accountant at (202)
551-3365 or
Christine Dietz, Senior Staff Accountant at (202) 551-3408 if you have any
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology
cc:      Julie Gao