United States securities and exchange commission logo August 15, 2023 William Wei Huang Chief Executive Officer GDS Holdings Ltd F4/F5, Building C, Sunland International No. 999 Zhouhai Road Pudong, Shanghai 200137 Re: GDS Holdings Ltd Form 20-F for the Fiscal Year Ended December 31, 2022 Filed April 4, 2023 File No. 001-37925 Dear William Wei Huang: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Technology cc: Daniel Ferteg