United States securities and exchange commission logo

                              September 18, 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
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2019
                                                            Filed April 17,
                                                            File No. 001-37925

       Dear Mr. Wei Huang:

               We have reviewed your August 28, 2020 response to our comment
letter and have the
       following comment. In our comment, we may ask you to provide us with
information so we may
       better understand your disclosure.

              Please respond to this comment 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
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this comment, we may have
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       July 31, 2020 letter.

       Form 20-F for the Fiscal Year Ended December 31, 2019

       Item 3. Key Information
       A. Selected Financial Data
       Non-GAAP Measures, page 4

   1.                                                   We note your response
to prior comment 1. As it appears you are attempting to show a
                                                        non-GAAP gross profit
measure, please revise to reconcile your adjusted NOI to GAAP
                                                        gross profit and label
accordingly. Also, expand your disclosures to further explain the
                                                        usefulness of this
measure to investors. Provide a draft of your revised disclosures in your
 William Wei Huang
GDS Holdings Limited
September 18, 2020
Page 2

       You may contact Megan Akst, Senior Staff Accountant, at 202-551-3407 or
Kindelan, Senior Staff Accountant, at 202-551-3564 with any questions.

FirstName LastNameWilliam Wei Huang                     Sincerely,
Comapany NameGDS Holdings Limited
                                                        Division of Corporation
September 18, 2020 Page 2                               Office of Technology
FirstName LastName