October 27, 2016

VIA EDGAR

Division of Corporation Finance

U.S. Securities & Exchange Commission

100 F Street N.E.

Mail Stop 4561

Washington, D.C. 20549

Ladies and Gentlemen:

On behalf of our client, GDS Holdings Limited, a company organized under the laws of the Cayman Islands (the “Company”), we enclose herewith for filing via EDGAR with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended (the “Securities Act”), an amendment (“Amendment No. 2”) to the Company’s registration statement on Form F-1 (the “Registration Statement”) and a free writing prospectus (“FWP”) reflecting certain amendments made to the  Company’s Registration Statement filed via EDGAR on October 19, 2016 (the “October 19 Filing”).

We enclose herewith five (5) courtesy copies of each of (i) Amendment No. 2, which has been marked to show changes to the October 19 Filing, and (ii) the FWP.

The Company has revised the October 19 Filing to include a revised Recent Developments section setting forth the Company’s preliminary unaudited interim financial information for the three months ended September 30, 2016, certain narrative explanations of the changes, and included a reconciliation of the non-GAAP measure.

*           *          *

If you have any question regarding the Registration Statement, please do not hesitate to contact me at +852-2514-7660 (work), +852-6440-3886 (mobile) or dfertig@stblaw.com (email) or David Lee at +852-2514-7655 (work), +852-9036-9375 (mobile) or dlee@stblaw.com (email).

Enclosures

2