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SEC Company Response from Aptorum Group Ltd (APM) (CIK 0001734005) (NIKI) — Oct 16, 2019

Aptorum Group Ltd (APM) (CIK 0001734005)
Date: Oct. 16, 2019 · CIK: 0001734005 · Accession: 0001213900-19-020423

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File numbers found in text: 333-232510

Date
Oct. 16, 2019
Author
Ian Huen
Form
CORRESP
Company
Aptorum Group Ltd (APM) (CIK 0001734005)

Letter

VIA EDGAR Division of Corporation Finance Office of Healthcare & Insurance Re: Aptorum Group Ltd. Amendment No. 2 to Registration Statement on Form F-1 Filed September 27, 2019 File No. 333-232510

Dear Sir and Madam:

Aptorum Group Limited (the “Company,” “Aptorum,” “we,” “us” or “our”) hereby transmits its response to the verbal comments our counsel, Louis Taubman, received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), on October 11, 2019, regarding our Registration Statement on Form F-1 previously submitted on July 2, 2019 and amended on August 16, 2019 and September 27, 2019 (the “Registration Statement”). For ease of reference, we have written our understanding of the Commission’s comments in this response and provided our response thereto. An amended F-1 submitted publicly accompanying this Response Letter is referred to as Form F-1.

1. Please revise the registration statement to remove reference to the website relating to where interested parties may find information related to the referenced Token offering. The information in this website contains more information than is permitted under Rule 902.

Response: We have removed all such references from the amendment being filed on this same date.

We thank the Staff for your review of the foregoing. If you have further comments, we ask that you forward them by electronic mail to our counsel, Louis Taubman at ltaubman@htflawyers.com or by telephone at (917) 512-0827.

/s/ Ian Huen

Ian Huen

CEO

cc: Louis Taubman

Hunter Taubman Fischer& Li LLC

Show Raw Text
CORRESP
1
filename1.htm

APTORUM
GROUP LIMITED

17th
Floor, Guangdong Investment Tower

148
Connaught Road Central

Hong
Kong

October
16, 2019

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Healthcare & Insurance

100
F Street, N.E.

Mail
Stop 4631

Washington,
DC 20549

Re:
Aptorum Group Ltd.

Amendment
No. 2 to Registration Statement on Form F-1

Filed
September 27, 2019

File
No. 333-232510

Dear
Sir and Madam:

Aptorum
Group Limited (the “Company,” “Aptorum,” “we,” “us” or “our”)
hereby transmits its response to the verbal comments our counsel, Louis Taubman, received from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”), on October 11, 2019, regarding our Registration
Statement on Form F-1 previously submitted on July 2, 2019 and amended on August 16, 2019 and September 27, 2019 (the “Registration
Statement”). For ease of reference, we have written our understanding of the Commission’s comments in this response
and provided our response thereto. An amended F-1 submitted publicly accompanying this Response Letter is referred to as Form
F-1.

 1. Please
                                         revise the registration statement to remove reference to the website relating to where
                                         interested parties may find information related to the referenced Token offering. The
                                         information in this website contains more information than is permitted under Rule 902.

Response:
We have removed all such references from the amendment being filed on this same date.

We
thank the Staff for your review of the foregoing. If you have further comments, we ask that you forward them by electronic mail
to our counsel, Louis Taubman at ltaubman@htflawyers.com or by telephone at (917) 512-0827.

    /s/
    Ian Huen

    Ian
        Huen

        CEO

    cc:
    Louis
    Taubman

Hunter
Taubman Fischer& Li LLC