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April 2, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-0405

Attention: Loan Lauren P. Nguyen, Legal Branch Chief

    Re:
    Future FinTech Group Inc.

        Registration Statement on Form S-3

        Response date February 7, 2019

        File No. 333-224686

Dear Ms. Nguyen:

Future FinTech Group Inc. (“FTFT”
or the “Company” and sometimes referred to as “we” or “our”) is filing a response to the SEC
Comment Letter, dated February 7, 2019 (the “Comment Letter”), in connection with complying with the issues and outstanding
disclosure items set forth therein. For convenience of reference, we have included in this response letter the same caption and
paragraph numbers, as well as the text of the comments, set forth in the Comment Letter followed by our responses thereto.

 General

 1. We note your response to comment 1 and reissue it in part. Disclosure at page 9 of your quarterly report 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 addition 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.

Response: The Shared Shopping Mall platform currently
does not support or accept any digital currency payments or exchanges, including mBTC and Bitcoin. In the future, we might consider
accepting mBTC or Bitcoin as the payment method on the Shared Shopping Mall. The Shared Shopping Mall platform is designed to be
a block-chain based shopping mall for merchants and goods, not the exchange of digital currencies, and it currently only accepts
payment from credit cards, Alipay and Wechat.

 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 platform will be required to pledge/deposit certain amounts of DCON token with the platform
“for the potential liabilities.” Please further explain this requirement and clarify the difference between your DCON
token and mBTC. Additionally, you indicate in response 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.

    Response:
The DCON Token is a block-chain based solution to establish the entry level requirements for the mBTC service providers, and it
is a method for them to receive the qualifications necessary to provide such services on the DCON platform. Any service provider
who plans to provide mBTC payment services shall publicly show the amount of DCON Tokens that it holds. If the service provider
does not have enough DCON Tokens (currently set at 100,000 DCON Tokens, but subject to change), the platform will not provide
him/her with the support and service for mBTC payment. The DCON Token minimum is intended to secure the performance of the service
providers’ obligations to customers on the platform. The entry level DCON Token requirement will be adjusted accordingly
based upon the demands for the mBTC service providers on the platform. We will include the risk factor disclosure discussing the
regulatory framework applicable to DCON Token, particularly with respect to their issuance and potential 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 holding 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.

    Response:
We do not believe that mBTC is a security as defined in Section 2(a)(1) of the Securities Act. The mBTC has a fixed exchange rate
of 1,000,000 for 1 BTC and it will not increase or decrease its value based upon the operations or development of the DCON platform.
The value of mBTC might increase or decrease in connection with the value of BTC, which is not currently considered to be a security
by the SEC. Any such fluctuations will be separate from the DCON platform and we do not believe that mBTC holders could have a
reasonable expectation of profit in connection with those changes. As such, we do not believe mBTC is an investment contract or
instrument in a common enterprise with a reasonable expectation of profit to be derived from the entrepreneurial or managerial
efforts of others. See SEC v. Edwards, 540 U.S. 389, 393 (2004); SEC v. W.J. Howey Co., 328 U.S. 293, 301 (1946);
see also United Housing Found., Inc. v. Forman, 421 U.S. 837, 852-53 (1975).

    In
June, 2018, Digipay Fintech Limited (“Digipay”), a wholly-owned subsidiary of the Company enter into an agreement
to purchase a 10% equity ownership interest in InUnion Chain Ltd. (“InUnion”) as well as 20,000,000 of the INU tokens
issued by InUnion. We are a minority owner of InUnion and InUnion Tokens and we do not believe we are well placed to conduct such
an analysis because we are not, and were not, involved in the creation, distribution or maintenance of the InUnion Token and do
not have knowledge of or access to the information that would be necessary to analyze whether the InUnion Tokens are securities
as defined in Section 2(a)(1) of the Securities Act.

 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 risk factor disclosure addressing the risks to maintaining an
exemption from registration under such Act.

    Response: We will revise our disclosure to include
a brief discussion of the Investment Company Act of 1940 and provide risk 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 developmental
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 real-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.

    Response:
In our response to prior comment 2, we indicated that we had not yet determined whether the Shared Shopping Mall will issue tokens
and that currently the Shared Shopping Mall did not plan to issue any token. In the investor presentation, we meant to communicate
that the individual stores on our platform may issue anti-counterfeit tokens (digital certificates) generated by the NRC block-chain.
When the third party stores on our platform reach a certain size and revenue level, we will assist them to generate anti-counterfeit
tokens using the NRC block-chain, which will be unique and attached to the products sold by such stores for identification purposes.

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We made the growth and trading volume projections
for the Shared Shopping Mall based upon our projections of the future number of VIP members on our platform, our increased efforts
for the online marketing campaign and on-the-ground promotions to attract customers into becoming VIP members. In China, revenues
received by the online retail market reached RMB 6.55 trillion, and it is expected the number in 2018 will have reached RMB 7.69
trillion based on the information from iMedia Group. Based on our sales and marketing department’s development plan and their
discussion with outside on-the-ground and online promotion teams, we anticipate that VIP members for the Shared Shopping Mall will
reach 1 million, 5 million and 50 million for 2019, 2020 and 2021, respectively. Only VIP members can open stores on our platform
and the minimum purchase amount in stores on our platform required to become a VIP member is RMB 5,000, which is subject to renewal
every 100 days. Based upon the projected number of VIP members, we estimate the revenue generated by all stores on our platform
for 2019 will be RMB 5 billion, excluding spending by the customers who did not reach the RMB 5,000 level (non-VIP members spending).
Based on that model and with the further development and increased functionality of the mall, we expect the annual spending for
a single VIP member in the mall will reach RMB 10,000 after 2019. Therefore, we estimate the revenues generated by all the stores,
including by VIP members and non-VIP members in the mall, for 2020 and 2021 will reach RMB 50 billion and RMB 500 billion, respectively.
Since the official launch of the Shared Shopping Mall version 1.0 in January 2019 , it has reached 3,000 VIP members and RMB 40 million of gross merchandise value, including amount of the orders, amounts deposited by members and transferred among
the members for all the stores on the platform over a period of three months while working with one promotion team. When version
2.0 of the Shared Shopping Mall is completed, the Company expects to work with 10 promotion teams to reach the 1 million VIP members.

If you have any further
comments or require any further information or if any questions should arise in connection with this submission, please call Mr.
Jeffrey Li at (202) 298-1735 or Ms. Chelsea Anderson at (206) 816-1312 at Garvey Schubert Barer, P.C.

    Very truly yours,

    /s/ Yongke Xue

    Yongke Xue

        Chief Executive Officer

        Future FinTech Group Inc.

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