United States securities and exchange commission logo

                              August 7, 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. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted August 3,
                                                            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

       Draft Registration Statement on Form F-1 submitted August 3, 2020

       ADS holders may not be entitled to a jury trial . . ., , page 62

   1.                                                   Please expand your
revisions to clarify here and on page 183 that investors cannot waive
                                                        compliance with the
federal securities laws, not merely that they will not be deemed to
                                                        waive such compliance.
       Liquidity and Capital Resources, page 92

   2.                                                   Please revise this
section to provide current information. We note, for example, the
                                                        proceeds raised from
the issuance of preferred shares in July 2020. Also, if there are
 Hongdi Brian Gu
August 7, 2020
Page 2
      material changes to the information in the table on page 95 since
December 31, 2019,
      please revise to discuss those changes. See Instruction 1 to Item 5.F of
Form 20-F.

3.    Please file the consent of Mr. Donghao Yang, as required by Rule 438 of
Regulation C.
        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
August 7, 2020 Page 2
cc:       Kevin P. Kennedy
FirstName LastName