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                              December 21, 2022

       Alex Wu
       Chief Financial Officer
       NaaS Technology Inc.
       Newlink Center, Area G, Building 7
       Huitong Times Square
       No.1 Yaojiayuan South Road, Chaoyang District
       Beijing 100024 China

                                                        Re: NaaS Technology
Inc.
                                                            Shell Company
Report on Form 20-F
                                                            Response Dated
October 17, 2022
                                                            File No. 001-38235

       Dear Alex Wu:

              We have reviewed your October 17, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       October 17, 2022 letter.

       Shell Company Report on Form 20-F Filed June 16, 2022

       Item 3. Key Information, page 6

   1.                                                   We note your response
to comment 3, including your proposed risk factor entitled    The
                                                        PRC government has
significant oversight over business operations conducted in China
                                                        and may intervene or
influence our operations at any time, which could result in a material
                                                        adverse change in our
operations and the value of our ADSs." In future filings, please
                                                        revise to include risk
factor disclosure, if material, about the laws and regulations in Hong
                                                        Kong that are
applicable to you and your operations, as well as the related risks and
                                                        consequences given that
you have operations and directors located in China.
 Alex Wu
FirstName LastNameAlex   Wu
NaaS Technology  Inc.
Comapany21,
December  NameNaaS
              2022    Technology Inc.
December
Page 2    21, 2022 Page 2
FirstName LastName
2.       We note your response to comment 4. Your discussion of the limitations
on cash transfers
         appears to discuss solely those in the PRC. In future filings, please
revise to also discuss
         limitations applicable to Hong Kong, given your Hong Kong subsidiary.
Please make
         consistent revisions throughout the document.
3.       We note your response to comment 5. Please expand your disclosure
related to the risks
         associated with cash transfers to encompass Hong Kong . Provide
prominent disclosure
         here, in the summary risk factors and risk factors sections to state
that, to the extent cash
         in the business is in PRC/Hong Kong or a PRC/Hong Kong entity, the
funds may not be
         available to fund operations or for other use outside of PRC/Hong Kong
due to
         interventions in or the imposition of restrictions and limitations on
the ability of you and
         your subsidiaries by the government to transfer cash. Acknowledge the
limitations upon
         transfer and tax obligations imposed by Hong Kong laws.
4.       We note your response to comment 7 and disclosure related to your
corporate history and
         restructuring along with risks facing the company and the offering
should a structure
         employing VIEs be implemented again. In future filings, please revise
to discuss risks
         related to your current corporate structure. Disclose that this
structure involves unique
         risks to investors. Your disclosure should acknowledge that Chinese
regulatory authorities
         could disallow this structure, which would likely result in a material
change in your
         operations and/or a material change in the value of your securities,
including that it could
         cause the value of such securities to significantly decline or become
worthless. Provide a
         cross-reference to your detailed discussion of risks facing the
company as a result of this
         structure.
5.       We note your response to comment 9. In future filings, please revise
to disclose each
         permission or approval including business licenses issued by the
relevant industrial and
         commercial administrative departments which you state were required
and obtained from
         Chinese authorities to operate your business and to offer securities
to foreign investors. In
         addition, state clearly whether any permissions or approvals have been
denied.
6.       We note your response to comment 13 regarding risks associated with
greater oversight by
         the CAC over data security and that it could have material adverse
impact on your
         business, prospects, financial condition and operating results. Please
revise to disclose that
         these risks could have a material impact on the value of your
securities. In addition,
         clearly state to what extent you believe that you are compliant with
the regulations or
         policies that have been issued by the CAC to date.
Dada Auto Inc.
Combined Statements of Loss and Other Comprehensive Loss, page F-49

7.       We note your response to comment 17 and your request to revise for
this error in your
         next annual report on Form 20-F. However, it appears that previously
issued financial
         statements are materially misstated and therefore, those financial
statements need to be
         restated and reissued. In addition, we note in your response to
comment 14 that selling
 Alex Wu
NaaS Technology Inc.
December 21, 2022
Page 3
         and marketing expenses for the year ended December 31, 2021 includes
RMB103.1
         million (US$16.2 million) of incentives to end-users representing the
part of incentive to
         end-users that exceeds the revenue generated from the same
transaction. Please explain to
         us your consideration of accounting for this portion of incentives as
a reduction of the
         transaction price (i.e., a reduction of revenue). Refer to IFRS 15.70
- 72.
2.15 Cost of Revenue, page F-62

8.       We note your response to comment 20 stating bandwidth and server
custody costs are
         primarily related to your research and development efforts. Please
tell us how much of
         your bandwidth and server custody costs relate to your operations or
generation of
         revenues. For your discussion of gross loss on page 73, please
eliminate, or revise to
         include a discussion of most directly comparable IFRS financial
measure, a fully-loaded
         IFRS gross loss, with greater prominence and a reconciliation between
the non-IFRS
         financial measure and the fully-loaded IFRS gross loss.
Notes to the Combined Financial Statements
2. Summary of Significant Accounting Policies
2.14.2 Contract Balances, page F-62

9.       We note your response and related revisions to comment 19 and reissue
our comment in
         part. Please revise to disclose revenue recognized in the reporting
period that was
         included in the contract liability balance at the beginning of the
period, and revenue
         recognized in the reporting period from performance obligations
satisfied (or partially
         satisfied) in previous periods. In addition, provide an explanation of
the significant
         changes in the contract balances during the reporting period.
       You may contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jennie Beysolow at 202-551-8108 or Dietrich King at 202-551-8071 with
any other
questions.



FirstName LastNameAlex Wu                                     Sincerely,
Comapany NameNaaS Technology Inc.
                                                              Division of
Corporation Finance
December 21, 2022 Page 3                                      Office of Trade &
Services
FirstName LastName