United States securities and exchange commission logo

                             May 7, 2021

       Peng Zhao
       Chief Executive Officer
       Kanzhun Ltd.
       18/F, GrandyVic Building Taiyanggong Middle Road
       Chaoyang Distict, Beijing 100020
       People   s Republic of China

                                                        Re: Kanzhun Ltd.
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted April 22,
                                                            CIK No. 0001842827

       Dear Mr. Zhao:

             We have reviewed your amended draft 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 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

             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
       comments. References to our prior comments refer to our letter dated May
7, 2021.

       Amendment No. 1 to Draft Registration Statement on Form F-1

       Summary, page 1

   1.                                                   Please incorporate your
response to prior comment 1 in your prospectus as it pertains to
                                                        why management believes
that the combination of both job seekers and enterprise users
                                                        in combined MAU or DAU
metrics is appropriate.
 Peng Zhao
FirstName  LastNamePeng Zhao
Kanzhun Ltd.
May  7, 2021NameKanzhun Ltd.
May 7,
Page 2 2021 Page 2
FirstName LastName
Business, page 120

2.       We note your response to prior comment 8 regarding your sales and
         expenditures. Please expand your discussion of your purchased online
traffic acquisition
         services, including the size and scope of such expenditures and
whether you have any
         material arrangements with vendors for such services.
Consolidated Financial Statements
Notes to Consolidated Financial Statements
2. Principal Accounting Activities
2.13 Revenue Recognition
Item Based Model, page F-22

3.       In your response to prior comment 15 you state that services delivered
in the form of
         various virtual tools mainly include bulk invite-sending, message
sending and other
         services regarding matching, and communicating with job seekers and
that revenue
         derived from these services is recognized at the point in time when
the services are
         provided to the enterprise customers, that is when the virtual tools
are consumed by the
         enterprise customers. Please clarify if your performance obligation is
to provide a
         specified quantity of the service that provides no continuing benefit
once consumed by the
         customer, or whether it is an obligation to make available an unknown
quantity of the
         service over the contract term or some longer period. If the latter,
please clarify the period
         of time over which customers can use these services once purchased,
and how you
         considered whether this is a stand-ready obligation to provide these
services that is
         satisfied over time because the customer simultaneously receives and
consumes the
         benefits from your agreement to make these services available to them.
Refer to ASC
9.Operating Leases, page F-33

4.       In your response to prior comment 18 you state that both amortization
of the right-of-
         use assets and the interest on lease liabilities are recorded in
operating costs and expenses
         in the Consolidated Statement of Comprehensive Loss. As such, it
appears that you are
         following the expense recognition guidance for finance leases as set
forth in ASC 842-20-
         25-5 and the illustrative example in ASC 842-20-55-27, rather than the
         recognition guidance for operating leases as set forth in ASC
842-20-25-6 and the
         illustrative example in ASC 842-20-55-29. Please clarify how your
recognition of lease
         expense for operating leases complies with the guidance in ASC 842.
       You may contact Laura Veator, Senior Staff Accountant, at (202) 551-3716
or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
comments on the financial statements and related matters. Please contact Edwin
Kim, Staff
Attorney, at (202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other
 Peng Zhao
Kanzhun Ltd.
May 7, 2021
Page 3

FirstName LastNamePeng Zhao
                               Division of Corporation Finance
Comapany NameKanzhun Ltd.
                               Office of Technology
May 7, 2021 Page 3
cc:       Z. Julie Gao, Esq.
FirstName LastName