Aptorum Group Ltd — Regulatory Filings 2020

Sep 30, 2020

Submission Data File

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----- Start of picture text ----- General InformationForm Type* CORRESP Contact Name Edgar Agents Contact Phone 732-780-5036Filer CIK* 0001734005 (Aptorum Group Ltd)Filer CCC* ******* Notify via Website only No Return Copy No(End General Information)Document InformationFile Count 1Document Name 1 ea127529-accelltr_aptorum.htmDocument Type 1 CORRESP Document Description 1 Acceleration Letter(End Document Information)Notifications Notify via Website only No E-mail 1 filings@edgaragents.com(End Notifications)----- End of picture text -----

Form Type: CORRESP APTORUM GROUP LTD

ea127529-accelltr_aptorum.htm Edgar Agents LLC

Page 1 09/29/2020 01:33 PM

APTORUM GROUP LIMITED

17[th ] Floor, Guangdong Investment Tower 148 Connaught Road Central Hong Kong

September 29, 2020

VIA EDGAR

U.S. Securities and Exchange Commission Division of Corporation Finance Office of Life Science 100 F Street, N.E. Mail Stop 4631 Washington, DC 20549

Re: Aptorum Group Ltd1 Registration Statement on Form F-1 Filed September 11, 2020 File No. 333-248743

Dear Sir and Madam:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Aptorum Group Limited hereby respectfully requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 2:00 p.m. Eastern Time on Tuesday, September 29, 2020, or as soon as thereafter practicable.

Please note that we acknowledge the following:

• should the Securities and Exchange Commission (the “Commission”) or the staff (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

• the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We thank the Staff for your review of the foregoing. If you have any further concerns, we ask that you forward them by electronic mail to our counsel, Louis Taubman at ltaubman@htflawyers.com or by telephone at (917) 512-0827.

/s/ Ian Huen

Ian Huen CEO

cc: Louis Taubman Hunter Taubman Fischer& Li LLC