DRSLTR

Simpson Thacher & Bartlett

LOGO

ICBC TOWER, 35TH FLOOR

3 GARDEN ROAD

HONG KONG

TELEPHONE: +852-2514-7600

FACSIMILE: +852-2869-7694

Direct Dial Number

(852) 2514-7620

E-mail Address

ygao@stblaw.com

November 23, 2020

CONFIDENTIAL AND VIA EDGAR

Draft Registration Statement

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Mail Stop 4561

Washington, D.C. 20549

Re:

XPENG INC.

Confidential Submission of the Draft Registration Statement on Form F-1

On behalf of our client, XPeng Inc., an exempted company incorporated under the laws of the Cayman Islands with limited liability (the “Company”), we hereby submit a draft Registration Statement on Form F-l (the “Draft Registration Statement”) relating to a proposed public offering in the United States of the Company’s Class A ordinary shares to be represented by American depositary shares (the “Proposed Offering”).

The Company’s initial registration statement on Form F-1 (File No. 333-242283) (the “IPO Registration Statement”) was declared effective by the Securities and Exchange Commission (the “Commission”) on August 26, 2020. The Draft Registration Statement was prepared based on the IPO Registration Statement and has included certain updates to the Company’s financial, business and other information since the effectiveness of the IPO Registration Statement.

The Draft Registration Statement is submitted via EDGAR to the Commission for review on a confidential basis in accordance with the procedures of the Commission. The Company confirms that the Draft Registration Statement is submitted prior to the end of the twelfth month following August 26, 2020, the effective date of the IPO Registration Statement, and that it will publicly file the Registration Statement on Form F-1 for the Proposed Offering (the “Registration Statement”) and the Draft Registration Statement such that these filings will be publicly available on the EDGAR system at least 48 hours prior to the requested effective time and date of the Registration Statement.

DANIEL FERTIG ADAM C. FURBER YI GAO ADAM S. GOLDBERG MAKIKO HARUNARI IAN C. HO JONATHAN HWANG ANTHONY D. KING CELIA C.L. LAM CHRIS K.H. LIN JIN HYUK PARK KATHRYN KING SUDOL CHRISTOPHER K.S. WONG

RESIDENT PARTNERS

SIMPSON THACHER & BARTLETT, HONG KONG IS AN AFFILIATE OF SIMPSON THACHER & BARTLETT LLP WITH OFFICES IN:

NEW YORK BEIJING HOUSTON LONDON LOS ANGELES PALO ALTO SÃO PAULO TOKYO WASHINGTON, D.C.