CORRESP 1 filename1.htm


17th Floor, Guangdong Investment Tower

148 Connaught Road Central

Hong Kong


September 29, 2020



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 or by telephone at (917) 512-0827.


  /s/ Ian Huen

Ian Huen



cc: Louis Taubman

Hunter Taubman Fischer& Li LLC