United States securities and exchange commission logo November 7, 2023 Dan Xie Chief Financial Officer UTStarcom Holdings Corporation 4th Floor, South Wing, 368 Liuhe Road Binjiang District, Hangzhou 310052 The People's Republic of China Re: UTStarcom Holdings Corporation Form 20-F for the Fiscal Year Ended December 31, 2022 File No. 001-35216 Dear Dan Xie: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Lan Lou