United States securities and exchange commission logo November 14, 2023 Craig Webster Chief Financial Officer Microvast Holdings, Inc. 12603 Southwest Freeway, Suite 300 Stafford, Texas 77477 Re: Microvast Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Response dated September 26, 2023 File No. 001-38826 Dear Craig Webster: We have reviewed your September 26, 2023 response to our comment letter and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our September 12, 2023 letter. Form SPDSCL-HFCAA-GOV filed September 26, 2023 General 1. We note your statement that you reviewed your register of shareholders and public filings made by your shareholders in connection with your required submission under paragraph (a). Please supplementally describe any additional materials that were reviewed and explain how you determined the absence of foreign government representation on your board. In addition, please tell us whether you relied upon any legal opinions or third party certifications such as affidavits as the basis for your submission. Craig Webster Microvast Holdings, Inc. November 14, 2023 Page 2 Please contact Jennifer Gowetski at 202-551-3401 or Andrew Mew at 202-551-3377 with any other questions. Sincerely, FirstName LastNameCraig Webster Division of Corporation Finance Comapany NameMicrovast Holdings, Inc. Disclosure Review Program November 14, 2023 Page 2 cc: Bill Nelson FirstName LastName