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                            June 9, 2023

       Ziyu Shen
       Chairman and Chief Executive Officer
       ECARX Holdings Inc.
       ECARX office, 2nd Floor South, International House
       1 St. Katharine   s Way
       London E1W 1UN
       United Kingdom

                                                        Re: ECARX Holdings Inc.
                                                            Registration
Statement on Form F-1
                                                            Filed May 12, 2023
                                                            File No. 333-271861

       Dear Ziyu Shen:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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.

       Registration Statement on Form F-1

       Prospectus Summary
       Permission Required from the PRC Authorities for Our Operations, page 6

   1.                                                   Please clearly state
whether the Trial Administrative Measures of Overseas Securities
                                                        Offering and Listing by
Domestic Companies apply to the current offering.
 Ziyu Shen
FirstName  LastNameZiyu Shen
ECARX Holdings   Inc.
Comapany
June 9, 2023NameECARX Holdings Inc.
June 9,
Page 2 2023 Page 2
FirstName LastName
Information Incorporated by Reference, page 55

2.       We note that you incorporate by reference certain information set
forth in Item 5 of Form
         F-1. Please note that you are not eligible to incorporate by reference
on Form F-1 until
         three years after the completion of your business combination. Refer
to General
         Instruction IV.D.1(b). Please revise to include the required
information within your Form
         F-1 registration statement. For further guidance, refer to the March
31, 2021 Staff
         Statement on Select Issues Pertaining to Special Purpose Acquisition
Companies.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Kathleen Krebs, Special Counsel, at 202-551-3350 or
Matthew Derby,
Legal Branch Chief, at 202-551-3334 with any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology
cc:      Shu Du, Esq.