January 8, 2020

Leslie Yu
Chief Executive Officer
QUHUO Ltd
3rd Floor, Block D, Tonghui Building
No. 1132 Huihe South Street, Chaoyang District
Beijing, People's Republic of China

       Re: QUHUO Ltd
           Amendment No. 2 to Draft Registration Statement on Form F-1
           Submitted December 18, 2019
           CIK No. 0001781193

Dear Mr. Yu:

      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.

Amendment No. 2 to Draft Registration Statement on Form F-1

Business
Our Solutions, page 110

1.     We note your disclosure on page 14 that "[you] generated approximately
96% of our total
       revenues from two major industry customers, Meituan and Ele.me" and on
page 16 that
       your industry customers typically require you "to adhere to their
standard form contracts,
       and there is little room to negotiate the terms and conditions that
deviate from such
       standard form contracts." In this regard, please revise your disclosure
here or elsewhere in
       your filing, to provide a summary of the key terms and conditions of the
material
       agreements with these industry customers. For example, given your
dependence on these
 Leslie Yu
QUHUO Ltd
January 8, 2020
Page 2
         industry customers and your inability to negotiate the terms of the
contracts, please
         discuss, key penalty fees and material liability and indemnification
provisions, if any.
Description of American Depositary Shares
Jurisdiction and Arbitration, page 171

2.       We note your revisions in response to prior comment 3 and we reissue
the comment in-
         part. Please revise to clearly disclose whether your exclusive forum
provision applies to
         claims under the U.S. federal securities laws. In this regard, we note
that your disclosure
         on pages 47 and 171 state that the mandatory arbitration and waiver of
jury trial
         provisions, respectively, include claims under the U.S. federal
securities laws. Please
         provide similar disclosure with regards to your exclusive forum
provision. If
         the provision does not apply to actions arising under the U.S. federal
securities laws,
         please ensure that the prospectus disclosure and such provision in the
deposit agreement
         state this clearly. As a related matter, please enhance your risk
factor disclosure on page
         47 to discuss, as you do for the mandatory arbitration provision, that
the exclusive forum
         provision may result in increased costs to bring a claim and may
discourage claims or
         limit investors' ability to bring a claim in a judicial forum that
they find favorable.



        You may contact Jennifer L pez, at 202-551-3792 or Lilyanna Peyser, at
2025-551-3222
with any questions.



FirstName LastNameLeslie Yu                                    Sincerely,
Comapany NameQUHUO Ltd
                                                               Division of
Corporation Finance
January 8, 2020 Page 2                                         Office of Trade
& Services
FirstName LastName