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                            October 4, 2022

       Mingjun Lin
       Chief Executive Officer
       Kaixin Auto Holdings
       9/F, Tower A, Dongjin International Center
       Huagong Road
       Chaoyang District, Beijing 100015
       People   s Republic of China

                                                        Re: Kaixin Auto
Holdings
                                                            Amendment No. 2 to
Annual Report on Form 20-F for the Year Ended
                                                            December 31, 2021
                                                            Filed September 8,
2022
                                                            File No. 001-38261

       Dear Mingjun Lin:

              We have reviewed your September 8, 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
       August 22, 2022 letter.

       Amendment No. 2 to Annual Report on Form 20-F

       Item 3. Key Information, page 4

   1.                                                   We note your disclosure
on page 33 that you "are regarded as the primary beneficiary of
                                                        the VIEs for accounting
purposes." In future filings, please revise your disclosure here
                                                        and on page 89 to also
include this information earlier in Item 3 when describing your
                                                        holding company
structure and contractual arrangements with the consolidated VIEs. In
                                                        this regard, any
references to control or benefits that accrue to you because of the VIE
                                                        should be limited to a
clear description of the conditions you have satisfied for
                                                        consolidation of the
VIE under U.S. GAAP. Additionally, your disclosure should clarify
 Mingjun Lin
Kaixin Auto Holdings
October 4, 2022
Page 2
       that you are the primary beneficiary of the VIE for accounting purposes.
Please tell us
       what your disclosure will look like.
2.     We note your disclosure on page 33 that "to the extent cash or assets in
the business are in
       the PRC/Hong Kong or a PRC/Hong Kong entity, funds or assets may not be
available to
       fund operations or for other use outside of the PRC/Hong Kong due to
interventions in or
       the imposition of restrictions and limitations on the ability of the
holding company, its
       subsidiaries, or the consolidated VIEs by the PRC government to transfer
cash or assets."
       In future filings, please revise your disclosure to also include this
information early in
       Item 3 and in the summary risk factors.
D. Risk factors.
Risks Related to Doing Business in China
The Chinese government exerts substantial influence..., page 38

3.     We note your disclosure on page 39 that your PRC legal counsel confirmed
the VIEs and
       their subsidiaries have obtained the requisite licenses and permits from
the Chinese
       authorities for the business operations in the PRC and that the VIEs and
their subsidiaries
       are not covered by permissions requirements from the CSRC, the CAC or
any other
       governmental agency that is required to approve the VIEs' operations. In
future filings,
       please disclose whether you are required to obtain permission or
approval from Chinese
       authorities to offer securities. In this regard, please disclose whether
you relied upon an
       opinion of counsel with respect to the conclusion that you do or do not
need permissions
       or approvals to offer securities to investors. If no opinion was
obtained, state as much and
       explain why such an opinion was not obtained. Please tell us what your
disclosure will
       look like.
       You may contact Robert Shapiro at 202-551-3273 or Lyn Shenk at
202-551-3380 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Jennifer L  pez Molina at 202-551-3792
with any other
questions.



                                                             Sincerely,
FirstName LastNameMingjun Lin
                                                           Division of
Corporation Finance
Comapany NameKaixin Auto Holdings
                                                           Office of Trade &
Services
October 4, 2022 Page 2
cc:       Ying Li, Outside Counsel at Hunter Taubman Fischer & Li
FirstName LastName