SecProbe.io

February 7, 2019

Yongke Xue
Chief Executive Officer
Future FinTech Group Inc.
23F, National Development Bank Tower
No. 2 Gaoxin 1st Road, Xi’an, PRC 710075

Re: Future FinTech Group Inc.
  Registration Statement on Form S-3
Response dated November 13 , 2018
  File No.  333-224686

Dear Mr. Yongke Xue:

We have reviewed your response letter 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 com ments 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, w e may have  additional comments.   Unless we note
otherwise, our references to prior comment  are to the comment  in our September 19 , 2018 letter .

General

1. We note your response to comment 1 and reissue it in part.  Disclosure at page 9 of your
quarterly rep ort on Form 10 -Q for the quarter ended September 30, 2018 states that the
Shared Shopping Mall is expected to be in operation in December 2018.  Please disclose
whether your Shared Shopping Mall platform will provide for other digital currencies, in
additi on to mBTC and Bitcoin, to be exchanged on that platform and, if so, describe all
such other digital currencies, their respective characteristics, and whether you believe
such platform will be required to be registered as a national securities exchange, an
alternative trading system or broker -dealer under the Securities Exchange Act of 1934.

2. Your response to comment 1 states that the DCON Token is different and separate from
mBTC and that any party that wants to provide exchange services on the DCON platfo rm
will be required to pledge/deposit certain amounts of DCON token with the platform “for

Yongke Xue
Future FinTech Group Inc.
February 7, 2019
Page 2

 the potential liabilities.”  Please furthe r explain this requirement and clarify the difference
between your DCON token and mBTC.  Additionally, you indicate in resp onse to
comment 2 that DCON tokens might be considered to be securities.  Please include risk
factor disclosure discussing the regulatory framework applicable to these assets,
particularly with respect to their issuance and trading in secondary markets.

3. We note your response to comment 2 and reissue it in part.  Please provide us with
analysis explaining whether mBTC and INU tokens are securities as defined in Section
2(a)(1) of the Securities Act.  In addition, please tell us whether you intend on hold ing
these tokens or any other digital assets.  Your analysis should specifically address the
distinct characteristics of each kind of token or other digital currency and how those
characteristics affect your conclusions.

4. We note you state that you do not consider yourself to be an investment company and
that you do not have an intention to become one in the future in your response to
comment 3.  Please revise your disclosure to include a brief discussion of the Investment
Company Act of 1940 and provide ri sk factor disclosure addressing the risks to
maintaining an exemption from registration under such Act.

Form 8 -K filed October 30, 2018

Exhibit 99.1

5. It appears that you generate revenues from your current fruit juice business and are in the
development al stages with your new focus on fintech and blockchain technology.  In your
response to prior comment 2, you indicate that you have not yet determined whether the
Shared Shopping Mall will issue tokens.  However, you state in your investor
presentation that the Shared Shopping Mall “will issue tokens by using the first rea l-name
blockchain technology developed by NRC.”  Please explain this apparent inconsistency
to us and ensure that your public statements are consistent with the disclosures in your
filings.   Additionally, please tell us your basis for including the growth and trading
volume projections for the Shared Shopping Mall for years 2019 – 2021 at pages 17 – 19
of your investor presentation given your developmental stage status.

Yongke Xue
Future FinTech Group Inc.
February 7, 2019
Page 3

 Please contact Karina V. Dorin, Staff Attorney, at (202) 551 -3763  or Loan Lauren
Nguyen, Legal Branch Chief, at (202) 551 -3642 w ith any questions.

Sincerely,

 /s/ Loan Lauren Nguyen  for

John Reynolds
Assistant Director
Office of Natural Resources