TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo August 8, 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 Response letter dated July 21, 2023 File No. 001-38587 Dear Shan-Nen Bong: We have reviewed your July 21, 2023 response to our comment letter. In order to help us more fully evaluate your responses to prior comments 1 and 2 regarding the Investment Company Act of 1940 (the Investment Company Act ), we have the following comments. 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 July 7, 2023 letter. Response letter dated July 21, 2023 Item 3. Key Information, page 3 1. Please update your analysis under Section 3(a)(1)(A) and 3(a)(1)(C) of the Investment Company Act to account for information as of the most recent fiscal quarter end. 2. Thank you for your detailed legal analysis regarding whether the Company meets the definition of an investment company under Section 3(a)(1)(A) of the Investment Company Act. However, in our prior questions, we also asked that you also provide a similarly detailed response regarding whether each of the Company s subsidiaries meets the definition of an investment company under Section 3(a)(1)(A) of the Investment Shan-Nen Bong Aurora Mobile Limited August 8, 2023 Page 2 Company Act. Please provide that analysis and, 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 as they apply to each of the Company s subsidiaries. 3. While we appreciate the summary calculations you provided in Appendix A of your response letter, the staff s question specifically asked that the Company identify each constituent part of the numerators and denominators when performing your analysis under section 3(a)(1)(C) of the Investment Company Act. Accordingly, please provide all relevant calculations under Section 3(a)(1)(C), identifying and describing each constituent part of the numerators and denominators for UA Mobile Limited, KK Mobile Limited, and JPush Information Consultation (Shenzhen) Co., Ltd. In doing so, please (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. 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 August 8, 2023 Page 2 Office of Technology FirstName LastName