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SEC Comment Letter for Aptorum Group Ltd (APM) (CIK 0001734005) (NIKI) — Jan 14, 2020

Aptorum Group Ltd (APM) (CIK 0001734005)
Date: Jan. 14, 2020 · CIK: 0001734005 · Accession: 0000000000-20-000314

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File numbers found in text: 333-235819

Date
January 13, 2020
Author
Irene Paik
Form
UPLOAD
Company
Aptorum Group Ltd (APM) (CIK 0001734005)

Letter

January 13, 2020 Ian Huen Chief Executive Officer and Executive Director Aptorum Group Ltd 17th Floor, Guangdong Investment Tower 148 Connaught Road Central Hong Kong Re:Aptorum Group Ltd Registration Statement on Form F-3 Filed January 6, 2020 File No. 333-235819 Dear Mr. Huen: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Irene Paik at 202-551-6553 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Louis Taubman

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January 13, 2020
Ian Huen
Chief Executive Officer and Executive Director
Aptorum Group Ltd
17th Floor, Guangdong Investment Tower
148 Connaught Road Central
Hong Kong
Re:Aptorum Group Ltd
Registration Statement on Form F-3
Filed January 6, 2020
File No. 333-235819
Dear Mr. Huen:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Irene Paik at 202-551-6553 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Louis Taubman