August 28, 2019

Jihong Liang
Chief Financial Officer
36Kr Holdings Inc.
5-6/F, Tower A1, Junhao Central Park Plaza
No. 10 South Chaoyang Park Avenue
Chaoyang District, Beijing, People's Republic of China, 100026

       Re: 36Kr Holdings Inc.
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted August 14, 2019
           CIK No. 0001779476

Dear Ms. Liang:

      We have reviewed your amended draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. References to prior comments are to those in our letter dated July
25, 2019.

Amendment No. 1 to Form F-1 Draft Registration Statement Submitted August 14,
2019

Prospectus Summary
Our Business, page 1

1.     We note your response to prior comment 1. Please clarify, as you state
in your response,
       that none of your Global Fortune 100 or Top 100 New Economy customers
individually
       contributed significantly to your 2018 revenue.
 Jihong Liang
FirstName LastNameJihong Liang
36Kr Holdings Inc.
Comapany Name36Kr Holdings Inc.
August 28, 2019
August 28, 2019 Page 2
Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Operating Data, page 78

2.       We note your response to prior comment 6. Please expand your
disclosures of the
         Average Monthly Page View to include a discussion that will provide an
understanding of
         the correlation of the Average Monthly Page View to the Cost per Day
and cost-per-
         advertisement models. You note in your response that page views are
apparently not a
         direct contributor to revenues but provide an indirect benefit that
"enhances the
         Company's brand awareness and influence." In addition, in view of your
Risk Factor
         disclosures that state, "Our business, prospects and financial results
may be affected by
         our relationship with third-party platforms" and that key operating
metrics "are calculated
         using our internal data as well as third-party platform's data, [and]
have not been validated
         by an independent third party, and may not be indicative of our future
operation results", it
         would appear to be material information to investors to include the
tabulation of page
         views between your self-operated platforms and third party platforms
to provide insight
         into your disclosed risks.
2. Significant Accounting Policies
(n) Revenue recognition, page F-21

3.       We note your response to prior comment 16 that articles are initially
displayed in a
         prominent position of the 36Kr Platforms for a very short period of
time and can only be
         accessed by search subsequent to this initial display. Please tell us
if revenues are only
         earned when the articles are initially displayed or if the customers
are also obligated to
         make additional payments when articles are displayed upon subsequent
searches. Please
         tell us how you evaluated whether revenues from the initial posting or
any subsequent
         search revenues represent performance obligations satisfied over time.
We refer you to
         ASC 606-10-25-27 and ASC 606-10-55-4 to 6.
        You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or
Craig Wilson,
Senior Assistant Chief Accountant, at (202) 551-3226 if you have questions
regarding comments
on the financial statements and related matters. Please contact Matthew
Crispino, Staff Attorney,
at (202) 551-3456 or Barbara C. Jacobs, Assistant Director, at (202) 551-3735
with any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Information Technologies
                                                               and Services