October 18, 2018

Yu Huang
Chief Executive Officer
China Index Holdings Limited
Tower A, No. 20 Guogongzhuang Middle Street
Fengtai District
Beijing 100070, People's Republic of China

       Re: China Index Holdings Limited
           Amendment No. 1 to
           Draft Registration Statement on Form F-1
           Submitted October 4, 2018
           CIK No. 0001749797

Dear Ms. Huang:

      We have reviewed your amended draft registration statement and have the
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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional

Amendment No. 1 to Draft Registration Statement

Use of Proceeds, page 77

1.     You state in the sixth paragraph that "[you] are currently able to fund
[your] operations in
       China by (1) contributing the subscribed registered capital of up to
US$500,000 in WFOE,
       and (2) providing shareholder loans to WFOE of an amount up to the
difference between
       its total investment amount and registered capital." With respect to the
second clause,
       please quantify the amount of shareholder loans that you are currently
able to fund.
 Yu Huang
FirstName LastNameYu Huang
China Index Holdings Limited
Comapany NameChina Index Holdings Limited
October 18, 2018
Page 2
October 18, 2018 Page 2
FirstName LastName
2.       We note your disclosure in the seventh paragraph regarding the various
approaches to
         make capital contributions or provide loans to WFOE or new
         enterprises. Please discuss the anticipated time frame for receipt of
and the likelihood you
         will obtain the necessary approvals with respect to the net proceeds
of this offering in
         comparison to the amounts that you may contribute or loan at this
Management's Discussion and Analysis of Financial Condition and Results of
Liquidity and Capital Resources
Operating Activities, page 124

3.       Please revise to discuss the factors contributing to the significant
increase in accounts
         receivable and days sales outstanding for the six months ended June
30, 2018.
Recent Accounting Pronouncements, page 127

4.       We note your revised disclosure in response to prior comment 12. Now
that you have
         updated the financial statements included in the filing to cover the
period of adoption,
         please indicate that results for reporting periods beginning after
January 1, 2018 are
         presented under the new revenue recognition.
Description of American Depository Shares, page 176

5.       Please provide us with a copy of the deposit agreement. In this
regard, we note your
         disclosure of the exclusive forum and mandatory arbitration
provisions. Please note that
         we may have additional comments upon review of the agreement and the
6.       In this regard, you state in the second to last paragraph on page 187
that the depositary
         may require disputes to be arbitrated under the rules of either the
American Arbitration
         Association or UNCITRAL. Please tell us and disclose the impact of
this provision on
         holders of your ADSs for claims under the federal securities laws.
Similarly revise the
         first full risk factor on page 72.
 Yu Huang
China Index Holdings Limited
October 18, 2018
Page 3

       You may contact Melissa Walsh, Staff Accountant, at 202-551-3224 or
Krikorian, Accounting Branch Chief, at 202-551-3488 if you have questions
comments on the financial statements and related matters. Please contact Donald
Attorney-Advisor, at 202-551-3680 or Nolan McWilliams, Attorney-Advisor, at
with any other questions.

FirstName LastNameYu Huang
                                                       Division of Corporation
Comapany NameChina Index Holdings Limited
                                                       Office of Information
October 18, 2018 Page 3                                and Services
FirstName LastName