United States securities and exchange commission logo

                                July 24, 2020

       Hongdi Brian Gu
       Vice Chairman and President
       XPENG INC.
       No. 8 Songgang Road, Changxing Street
       Cencun, Tianhe District, Guangzhou
       Guangdong 510640
       People   s Republic of China

                                                        Re: XPENG INC.
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted July,
                                                            CIK No. 0001810997

       Dear Mr. Gu:

             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

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

       Risk Factors, page 15

   1.                                                   Notwithstanding your
response to prior comment 3 that you do not intend to utilize
                                                        exemptions for
controlled companies, it continues to appear that those exemptions will be
                                                        available to you at any
time should you decide to invoke them. As such, it also continues
                                                        to appear that this
availability creates an additional risk to investors, separate from the risk
                                                        related to following
home country governance practices. Therefore, please revise to
                                                        describe the exemptions
available to controlled companies and the related risks to
 Hongdi Brian Gu
July 24, 2020
Page 2
The COVID-19 outbreak . . ., , page 19

2.    We note your revisions in response to prior comment 5. To provide
investors with a better
      understanding of the magnitude of the effect, please revise to compare
the number of
      units you disclose with the number of units sold during the same months
in 2019.
        You may contact Kevin Stertzel at (202) 551-3723 or John Cash,
Accounting Branch
Chief, at (202) 551-3768 if you have questions regarding comments on the
financial statements
and related matters. Please contact Geoff Kruczek at (202) 551-3641 or Jay
Ingram, Legal
Branch Chief, at (202) 551-3397 with any other questions.

FirstName LastNameHongdi Brian Gu
                                                          Division of
Corporation Finance
Comapany NameXPENG INC.
                                                          Office of
July 24, 2020 Page 2
cc:       Kevin P. Kennedy
FirstName LastName