Aptorum Group Ltd — Regulatory Filings 2018

Nov 30, 2018

CORRESP 1 filename1.htm

APTORUM GROUP LIMITED

17 th Floor, Guangdong Investment Tower

148 Connaught Road Central

Hong Kong

November 30, 2018

VIA EDGAR CORRESPONDENCE

Christine Westbrook

U.S. Securities and Exchange Commission

Division of Corporate Finance

Office of Real Estate and Commodities

100 F Street, N.E.

Mail Stop 3233

Washington, DC 20549

| Re: |
| --- |
| Registration
Statement on Form F-1/A (File No. 333-227198) REQUEST
FOR ACCELERATION OF EFFECTIVENESS |

Ladies and Gentlemen:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Aptorum Group Limited . (the “ Company ”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1/A (the “ F-1 Registration Statement ”) be accelerated to and that the F-1 Registration Statement become effective at 4:30pm, Eastern Time, on December 3, 2018, or as soon thereafter as practicable.

If there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request of acceleration of the effectiveness of the F-1 Registration Statements in accordance with Rule 461. The request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Hunter Taubman Fischer & Li LLC.

The Company hereby acknowledges the following:

● should the Securities and Exchange Commission (the “ Commission ”) or the staff of the Commission (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.

If you have any further questions, please contact Louis Taubman, Esq., at +1 (917) 512-0827, from the Company’s U.S. counsel, Hunter Taubman Fischer & Li LLC.

Very truly yours,
Aptorum Group Limited
By:	/s/
Ian Huen
Name:	Ian
Huen
Title:	Chief Executive
Officer