SecProbe.io

CORRESP
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filename1.htm

APTORUM
GROUP LIMITED

17th
Floor, Guangdong Investment Tower

148
Connaught Road Central

Hong
Kong

November
30, 2018

VIA
EDGAR CORRESPONDENCE

Christine
Westbrook

U.S.
Securities and Exchange Commission

Division
of Corporate Finance

Office
of Real Estate and Commodities

100
F Street, N.E.

Mail
Stop 3233

Washington,
DC 20549

    Re:
    Aptorum
    Group Limited

    Registration
        Statement on Form F-1/A (File No. 333-227198)

        REQUEST
        FOR ACCELERATION OF EFFECTIVENESS

Ladies
and Gentlemen:

In
accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Aptorum Group Limited.
(the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement
on Form F-1/A (the “F-1 Registration Statement”) be accelerated to and that the F-1 Registration Statement
become effective at 4:30pm, Eastern Time, on December 3, 2018, or as soon thereafter as practicable.

If
there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which
case the Company may be making an oral request of acceleration of the effectiveness of the F-1 Registration Statements in accordance
with Rule 461. The request may be made by an executive officer of the Company or by any attorney from the Company’s U.S.
counsel, Hunter Taubman Fischer & Li LLC.

The
Company hereby acknowledges the following:

    ●
    should
    the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (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.

If
you have any further questions, please contact Louis Taubman, Esq., at +1 (917) 512-0827, from the Company’s U.S. counsel,
Hunter Taubman Fischer & Li LLC.

    Very truly yours,

    Aptorum Group Limited

    By:
    /s/
        Ian Huen

    Name:
    Ian
Huen

    Title:
    Chief Executive
    Officer