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                             November 30, 2023

       Shuo Shi
       Chief Executive and Operations Officer
       WiMi Hologram Cloud Inc.
       Room #2002, Building A, Wentley Center
       1st West Dawang Road, Chaoyang District
       Beijing, The People   s Republic of China, 100020

                                                        Re: WiMi Hologram Cloud
Inc.
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            Response dated
November 13, 2023
                                                            File No. 001-39257

       Dear Shuo Shi:

              We have reviewed your November 13, 2023 response to our comment
letter and have the
       following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

               After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our October 30, 2023
       letter.

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

       Item 18. Financial Statements
       Note 13. Goodwill, page F-50

   1.                                                   We note your responses
to prior comments 1 and 2, however, it remains unclear to us how
                                                        you determined that the
fair value of your reporting units was approximately $192 million
                                                        when the company   s
total market capitalization was only $64 million at the time of your
                                                        goodwill analysis. We
further note that the company   s total market capitalization has
                                                        remained significantly
below the total fair value of your reporting units throughout fiscal
                                                        2023. Please address
the following:
                                                            The growth rate
projections used in your analysis do not appear to be in line with
                                                            historical revenue
trends for the consolidated company and specifically
                                                            the AR advertising
services segment for which Shenzhen Yidian and Shenzhen Yitian
 Shuo Shi
WiMi Hologram Cloud Inc.
November 30, 2023
Page 2
              are included. Provide all evidence used to support the expected
revenue growth for
              both reporting units or explain in further detail the basis for
such assumptions.
                Describe the trends in these two reporting units over the last
several years and explain
              how such trends factored into your assumptions.
                Tell us whether your revenue growth projections still reflect
management's view of
              future performance. If so, explain how you considered the
decrease in Holographic
              AR advertising revenue during the first half of fiscal 2023
compared to your growth
              rate projections of 200% and 707% for the Shenzhen Yidian and
Shenzhen Yitian
              reporting units, respectively.
                Explain how the discount rate used in your valuation was
determined and how
              management determined such rate was appropriate.
                Tell us whether a sensitivity analysis was performed for the
Shenzhen Yidian and
              Shenzhen Yitian reporting units and if so, what those results
were.
                Tell us whether you performed any interim impairment analysis
or tell us how you
              determined that such analysis was not necessary.
2.       Please clarify whether the December 31, 2022 carrying value for each
reporting unit
         included in your response to prior comment 1 includes the goodwill
allocated to each
         respective reporting unit. In this regard, it is unclear why you are
adjusting for net
         goodwill in calculating the percentage by which fair value exceeds
carrying value. Please
         explain or revise.
       Please contact Megan Akst at 202-551-3407 or Kathleen Collins at
202-551-3499 if you
have questions regarding comments on the financial statements and related
matters.



FirstName LastNameShuo Shi                                      Sincerely,
Comapany NameWiMi Hologram Cloud Inc.
                                                                Division of
Corporation Finance
November 30, 2023 Page 2                                        Office of
Technology
FirstName LastName