United States securities and exchange commission logo November 2, 2020 William Wei Huang Chief Executive Officer GDS Holdings Limited F4/F5, Building C, Sunland International No. 999 Zhouhai Road Pudong, Shanghai 200137 People's Republic of China Re: GDS Holdings Limited Form 20-F for the Fiscal Year Ended December 31, 2019 Filed April 17, 2020 File No. 001-37925 Dear Mr. 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