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                             July 17, 2023

       Kevin Richard Benning
       Property General Manager
       Studio City International Holdings Limited
       38th Floor, The Centrium
       60 Wyndham Street
       Central
       Hong Kong

                                                        Re: Studio City 
International Holdings Ltd
                                                            Amendment No. 2 to 
Registration Statement on Form F-3
                                                            Filed July 7, 2023
                                                            File No. 333-261406

       Dear Kevin Richard Benning:

             We have reviewed your amended 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 amending your registration 
statement and providing the
       requested information. 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
       response.

              After reviewing any amendment to your registration statement and 
the information you
       provide in response to these comments, we may have additional comments. 
Unless we note
       otherwise, our references to prior comments are to comments in our March 
17, 2022 letter.

       Form F-3/A filed July 7, 2023

       Cover Page

   1.                                                   We note your response 
to comment 3; however, please revise the last bulleted definition
                                                        on page 1 to clarify 
which entity the disclosure is referencing and which subsidiaries or
                                                        entities are conducting 
the business operations.
 Kevin Richard Benning
FirstName
Studio CityLastNameKevin    RichardLimited
                                    Benning
            International Holdings
Comapany
July       NameStudio City International Holdings Limited
     17, 2023
July 17,
Page  2 2023 Page 2
FirstName LastName
General

2.       Please update your disclosure to discuss the China Securities 
Regulatory Commission
         (CSRC) announcement of the implementation of the Trial Administrative 
Measures of
         Overseas Securities Offering and Listing by Domestic Companies which 
became effective
         on March 31, 2023.
      Please contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 
202-551-
3713 with any questions.



                                                           Sincerely,

                                                           Division of 
Corporation Finance
                                                           Office of Real 
Estate & Construction
cc:      Tim Cruickshank