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                            July 7, 2023

       Shan-Nen Bong
       Chief Financial Officer
       Aurora Mobile Limited
       14/F, China Certification and Inspection Building
       No. 6, Keji South 12th Road , Nanshan District
       Shenzhen, Guangdong 518057
       People   s Republic of China

                                                        Re: Aurora Mobile
Limited
                                                            Form 20-F filed on
April 18, 2023
                                                            File No. 001-38587

       Dear Shan-Nen Bong:

              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 18, 2023

       Item 3. Key information, page 3

   1.                                                   Please provide a
detailed legal analysis regarding whether the Company and its
                                                        subsidiaries meet the
definition of an    investment company    under Section 3(a)(1)(A) of
                                                        the Investment Company
Act of 1940 (   Investment Company Act   ). In your response,
                                                        please address, in
detail, each of the factors outlined in Tonapah Mining Company of
                                                        Nevada, 26 SEC 426
(1947) and provide legal and factual support for your analysis of
                                                        each such factor.
   2.                                                   Please provide a
detailed legal analysis regarding whether the Company or any of its
                                                        subsidiaries meet the
definition of an    investment company    under Section 3(a)(1)(C) of
                                                        the Investment Company
Act. In your response, please include all relevant calculations
                                                        under Section
3(a)(1)(C), identifying each constituent part of the numerators and
 Shan-Nen Bong
FirstName   LastNameShan-Nen  Bong
Aurora Mobile   Limited
Comapany
July 7, 2023NameAurora Mobile Limited
July 7,2 2023 Page 2
Page
FirstName LastName
         denominators. Please also (i) specifically describe the types of
assets included within
            cash and cash equivalents,       long-term investments    and
short-term investments    on
         your balance sheet and (ii) describe and discuss their proposed
treatment for purposes of
         section 3(a)(1)(C), as well as any other substantive determinations
and/or
         characterizations of assets that are material to your calculations.
Finally, please include a
         legal analysis of whether the interests held by the Company in its VIE
are    investment
         securities    for purposes of Section 3(a)(2) of the Investment
Company Act.
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections,
page 152

3.       We note your statement that you reviewed your register of members and
public filings
         made by your shareholders in connection with your required submission
under paragraph
         (a). Please supplementally describe any additional materials that were
reviewed and tell us
         whether you relied upon any legal opinions or 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).
4.       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.
5.       We note that your disclosures pursuant to Items 16I(b)(2), (b)(3), and
(b)(5) are provided
         for    Aurora Mobile Limited or the VIE.    We also note that your
list of subsidiaries and
         consolidated variable interest entity in Exhibit 8.1 appears to
indicate that you have
         subsidiaries in Hong Kong, mainland China and countries outside China
that are not
         included in your VIE. Please note that Item 16I(b) requires that you
provide disclosures
         for yourself and your consolidated foreign operating entities,
including variable interest
         entities or similar structures.
             With respect to (b)(2), please supplementally clarify the
jurisdictions in which your
              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.
             With respect to (b)(3) and (b)(5), please provide the required
information for you and
              all of your consolidated foreign operating entities in your
supplemental response.
6.       With respect to your disclosure pursuant to Item 16I(b)(5), we note
that you have included
         language that such disclosure is    to our knowledge.    Please
supplementally confirm
         without qualification, if true, that your articles and the articles of
your consolidated
         foreign operating entities do not contain wording from any charter of
the Chinese
 Shan-Nen Bong
Aurora Mobile Limited
July 7, 2023
Page 3
         Communist Party.
       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 Austin Pattan, Staff
Attorney, at 202-
551-6756, or Larry Spirgel, Office Chief, at 202-551-3815 with any other
questions.



FirstName LastNameShan-Nen Bong                            Sincerely,
Comapany NameAurora Mobile Limited
                                                           Division of
Corporation Finance
July 7, 2023 Page 3                                        Office of Technology
FirstName LastName