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                            January 31, 2023

       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, The People's Republic of China

                                                        Re: NaaS Technology
Inc.
                                                            Shell Company
Report on Form 20-F
                                                            Response Dated
January 6, 2023
                                                            File No. 001-38235

       Dear Alex Wu:

              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.

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

       Item 3. Key Information, page 3

   1.                                                   We note your response
to comment 3. Please revise your summary of risk factors and risk
                                                        factors section, as you
do in the Cash and Asset Flows through Our Organization section
                                                        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.
   2.                                                   We note your response
to comment 5. Please revise to disclose each of the required
                                                        permissions or
approvals that you state have been obtained for your business operations
                                                        and for the offering of
your securities.
 Alex Wu
NaaS Technology Inc.
January 31, 2023
Page 2
Combined Statements of Loss and Other Comprehensive Loss, page F-49

3.       We note your response to comment 7 and reissue our comment in part
with a
         clarification. Please tell us how you determined it was appropriate to
classify incentives
         given to end-users that exceeded the revenue generated from the same
transaction from
         revenue to selling and marketing expenses, including any specific
accounting guidance
         you utilized to support such classification. Otherwise, it appears
that incentives that were
         classified as selling and marketing expenses for the year ended
December 31, 2021
         (RMB103.1 million (US$16.2 million)) should also be classified as a
reduction of the
         transaction price (i.e., a reduction of revenue).

General

4.       We have reviewed your responses to comments 8 and 9. We await your
planned
         amendment to the Shell Company Report and may issue comments based on
the
         disclosures included therein.
        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 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
January 31, 2023 Page 2                                         Office of Trade
& Services
FirstName LastName