September 10, 2018 William Wei Huang Chief Executive Officer GDS Holdings Limited 2/F, Tower 2, Youyou Century Place 428 South Yanggao Road Pudong, Shanghai 200127 People's Republic of China Re: GDS Holdings Limited Form 20-F for the Fiscal Year Ended December 31, 2017 Filed March 29, 2018 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 Information Technologies and Services