United States securities and exchange commission logo December 23, 2021 Yanzhuan Zheng Chief Financial Officer Microvast Holdings, Inc. 12603 Southwest Freeway, Suite 210 Stafford, Texas 77477 Re: Microvast Holdings, Inc. Amendment No. 3 to Registration Statement on Form S-1 Filed December 14, 2021 File No. 333-258978 Dear Mr. Zheng: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our November 18, 2021 letter. Amendment No. 3 to Registration Statement on Form S-1 Filed December 14, 2021 Prospectus Cover Page, page i 1. Provide a description of how cash is transferred through your organization and disclosure regarding your intentions to distribute earnings or settle amounts owed under your agreements. State whether any transfers, dividends, or distributions have been made to date. Prospectus Summary, page 1 2. Please revise both the risk factors summary and the Risk Factors section to move forward the risks related to doing business in the PRC so that such risks are prominently disclosed within each section in relation to other identified material risks. Yanzhuan Zheng Microvast Holdings, Inc. December 23, 2021 Page 2 Please contact Sherry Haywood, Staff Attorney at (202) 551-3345 or Asia Timmons- Pierce, Special Counsel at (202) 551-3754 with any questions. FirstName LastNameYanzhuan Zheng Sincerely, Comapany NameMicrovast Holdings, Inc. Division of Corporation Finance December 23, 2021 Page 2 Office of Manufacturing FirstName LastName