January 31, 2020

Philip Jiaqi Kuai
Chief Executive Officer
Dada Nexus Limited
22/F, Oriental Fisherman's Wharf
No.1088 Yangshupu Road
Yangpu District, Shanghai
People's Republic of China

       Re: Dada Nexus Limited
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted January 17, 2020
           CIK No. 0001793862

Dear Mr. Kuai:

      We have reviewed your amended draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 1 to Draft Registration Statement on Form F-1

Conventions that Apply to this Prospectus, page 7

1.     We note your response to prior comment 3. Please disclose that you treat
each account as
       a separate consumer even though certain consumers may have set up more
than one
       account.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Factors Affecting Our Results of Operations, page 79

2.     We note your response to prior comment 9. Please discuss the reason(s)
behind the
 Philip Jiaqi Kuai
Dada Nexus Limited
January 31, 2020
Page 2
      significant drop in your retention rate from 2018 to 2019.
3.    We note your response to prior comment 7. Please disclose the reasons
behind the
      decrease in the number of orders delivered in the twelve months ended
September 30,
      2018 and December 31, 2018.
Key Components of Results of Operations, page 82

4.    You disclose on page 82 that revenues from JDDJ are earned from four
different types of
      services. Please revise your table on page 83 to separately quantify JDDJ
revenues from
      delivery services where you act as a principal and JDDJ commission fee
revenues where
      you act as an agent. Please also clarify which types of services are
included in other
      services revenues of RMB23,402 for the year ended December 31, 2018.
Similarly revise
      your table on page F-19.
5.    In your discussion of "fulfillment" expenses on page 84, and elsewhere as
      appropriate, please separately define, discuss and quantify expenses
related to rider
      incentives when you act as the principal in the delivery transaction.
Furthermore, please
      separately define, discuss and quantify expenses related to "negative
revenue" when you
      act as agent in the delivery transaction that results in a loss.
Consolidated Statements of Operations and Comprehensive Loss, page F-5

6.    We note your response and revised disclosures to prior comment 16. Please
revise and
      present a line item that separately states the amounts of "cost of
services" in accordance
      with Rule 5-03.2 of Regulation S-X. Also separately disclose and provide
a related
      discussion in MD&A.
        You may contact Joseph Cascarano, Senior Staff Accountant, at (202)
551-3376 or Inessa
Kessman, Senior Staff Accountant, at (202) 551-3371 if you have questions
regarding comments
on the financial statements and related matters. Please contact Jeff Kauten,
Staff Attorney,
at (202) 551-3447 or Larry Spirgel, Office Chief, at (202) 551-3815 with any
other questions.



                                                            Sincerely,
FirstName LastNamePhilip Jiaqi Kuai
                                                            Division of
Corporation Finance
Comapany NameDada Nexus Limited
                                                            Office of
Technology
January 31, 2020 Page 2
cc:       Z. Julie Gao, Esq.
FirstName LastName