United States securities and exchange commission logo





                              August 8, 2023

       Yongyi Zhang
       Chief Financial Officer
       Cango Inc.
       8F, New Bund Oriental Plaza II
       556 West Haiyang Road , Pudong New Area
       Shanghai 200124
       People   s Republic of China

                                                        Re: Cango Inc.
                                                            Form 20-F filed on
April 26, 2023
                                                            File No. 001-38590

       Dear Yongyi Zhang :

              We have limited our review of your filing to the financial
statements and related
       disclosures 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.

       Form 20-F filed on April 26, 2023

       Item 3. Key information
       Our Corporate Structure, page 4

   1.                                                   We noted your
disclosure that you engage in value-added telecommunications services, or
                                                        VATS, namely
value-added online services for platform participants within the key
                                                        information section,
and we also note telecommunications services related disclosures
                                                        beginning pages
48,55,58, 120 and 122. However, based on your financial statements
                                                        disclosures and the
rest of the filing disclosures, you operates as an automotive transaction
                                                        service platform that
connects dealers, original equipment manufacturer, financial
                                                        institutions, car
buyers, and other industry participants in the People's Republic of China.
                                                        Please advise or revise
your conflicting disclosures.
       Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 201
 Yongyi Zhang
Cango Inc.
August 8, 2023
Page 2

2.       We note the certification by your Chief Executive Officer in
connection with your
         required submission under paragraph (a). Please supplementally
describe the materials
         that were reviewed and tell us whether you relied upon any legal
opinions or additional
         third party certifications such as affidavits as the basis for your
submission. In your
         response, please provide a similarly detailed discussion of the
materials reviewed and
         legal opinions or third party certifications relied upon in connection
with the required
         disclosures under paragraphs (b)(2) and (3).
3.       In order to clarify the scope of your review, please supplementally
describe the steps you
         have taken to confirm that none of the members of your board or the
boards of your
         consolidated foreign operating entities are officials of the Chinese
Communist Party. For
         instance, please tell us how the board members    current or prior
memberships on, or
         affiliations with, committees of the Chinese Communist Party factored
into your
         determination. In addition, please tell us whether you have relied
upon third party
         certifications such as affidavits as the basis for your disclosure.
4.       Please note that Item 16I(b) requires that you provide disclosures for
yourself and all of
         your consolidated foreign operating entities. With respect to (b)(2),
please supplementally
         clarify the jurisdictions in which your material consolidated foreign
operating entities are
         organized or incorporated and tell us the percentage of your shares or
the shares of your
         consolidated operating entities owned by governmental entities in each
foreign
         jurisdiction in which you have consolidated operating entities. In
this regard we note that
         Exhibit 8.1 indicates that you have subsidiaries in Hong Kong.
       In closing, 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 Becky Chow, Staff Accountant at 202-551-6524, or
Stephen Krikorian,
Accounting Branch Chief, at 202-551-3488 if you have questions regarding
comments on the
financial statements and related matters. Please contact Kyle Wiley, Staff
Attorney, at 202- 551-
6756, or Larry Spirgel, Office Chief, at 202-551-34870 with any other
questions.



FirstName LastNameYongyi Zhang                                 Sincerely,
Comapany NameCango Inc.
                                                               Division of
Corporation Finance
August 8, 2023 Page 2                                          Office of
Technology
FirstName LastName