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Asia
Times Holdings Limited

December 11, 2018

Via Edgar

Mr. Larry Spirgel

Assistant Director

Division of Corporation Finance

U.S. Securities and Exchange
Commission

    Re:
    Asia Times Holdings Limited

    Draft Registration Statement on Form F-1

Submitted on November 28,
2018

    CIK No. 0001755058

Dear Mr. Spirgel:

This letter is in response to
the letter dated December 4, 2018 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Asia Times Holdings Limited (the “Company”, “we”, “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. A Registration Statement on Form
F-1 (the “Registration Statement”) is submitted separately to accompany this letter reflecting the Staff’s comments.

Use of Proceeds, page
33

1. We note your response to
prior comment six. Revise to explain how your uses of proceeds can "generally be accomplished" without transferring funds
into the PRC.

In response to the Staff’s
comment, we have revised the disclosure on page 33 of the Registration Statement.

Regulations

PRC Laws and Regulations
relating to Foreign Exchange, page 70

2. Clarify whether proceeds
raised in this offering may be subject to the Circulars 19 and 16 if they are used as capital contributions to Huaya and the Chinese
operating companies.

In response to the Staff’s
comment, we have revised the disclosure on page 73 of the Registration Statement.

General

3. We note your response
to prior comment 15. In addition to the references to the variouspage numbers in the Frost & Sullivan reports you cite you
have provided in Annex A, please provide the actual underlying support materials as part of your supplemental response.

In response to the Staff’s comment,
the Company has enclosed (1) an amended Annex A to this letter presenting the relevant portions of the Frost & Sullivan
Industry Market Research Report supporting the corresponding statements in the Registration Statement, and (2) as a new Annex
B to this letter, the Frost & Sullivan Industry Market Research Report as prepared at the request of the Company in connection
with the proposed offering.

     1

Address: Room 3803, Dachong International Centre, 39 Tonggu Road, Nanshan district, Shenzhen, China

Tel: (+86) 0755-8695-0818

In responding to your comments,
the Company acknowledges that:

● the Company is responsible
for the adequacy and accuracy of the disclosure in the filing;

● Staff comments or changes to disclosure in
response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

● the Company may not
assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws
of the United States.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq.,
of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.

Very truly yours,

    Very truly yours,

    /s/ Qiuli Wang

    Name: Qiuli Wang

    Title: Chief Executive Officer

Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

     2

Address: Room 3803, Dachong International Centre, 39 Tonggu Road, Nanshan district, Shenzhen, China

Tel: (+86) 0755-8695-0818

Annex A

    Items
    Statement in Draft Amendment No.1
    Page Number in Draft Amendment No.1
    Page Number in the Market Research Report by Frost & Sullivan

    A
    The China capital market has experienced rapid growth ever since the global financial crisis occurred in late 2008. PRC domestic companies are looking for opportunities in China as well as abroad to increase their presence in the global market. It is expected that financing activities such as mergers and acquisitions, and initial public offerings, will become more prosperous than before. Financial consultancy services are particularly important in these kind of transactions as consultants can assist their clients with strategy planning and other professional services. The financial consultancy market has been growing rapidly in recent years driven by factors including rising prosperous M&A and financing activities, strong government support in terms of regulating policies and measures, enhanced participation of more parties and growing awareness of the importance of financial consultancy by downstream enterprises. Based on expert interviews and primary market research conducted by Frost & Sullivan, it is estimated that, from 2013 to 2017, the overall financial consultancy market in China increased from RMB136.9 billion to RMB257.2 billion at a compound annual growth rate, or CAGR, of 17.1%; and looking forward, it is forecasted that the economy in China will maintain a steady growth momentum over the next 5 years, and by 2022 the financial consultancy market is expected to reach RMB506.0 billion, at a CAGR of 14.2%.
    Page 2
    Page 17

    B

        According to the International Monetary Fund (IMF), the

        nominal GDP of China increased from RMB59,696.3 billion in 2013
        to RMB81,133.0 billion in 2017 at a CAGR of 8.0%. Driven by strong domestic consumption, ambitious government policy direction
        and active financing activities, the overall economy in China is expected to be at a CAGR of 8.2% from 2018 to 2022 (according
        to Frost & Sullivan). Driven by the social and economic development in China, the overall direct investment (inward and outward)
        in China increased from USD 123.9 billion in 2013 to approximately USD 133.7 billion in 2016, representing a CAGR of 2.6%

    Page 48
    Page 5

     3

Address: Room 3803, Dachong International Centre, 39 Tonggu Road, Nanshan district, Shenzhen, China

Tel: (+86) 0755-8695-0818

    A
    The China capital market has experienced rapid growth ever since the global financial crisis occurred in late 2008. PRC domestic companies are looking for opportunities in China as well as abroad to increase their presence in the global market. It is expected that financing activities such as mergers and acquisitions, and initial public offerings, will become more prosperous than before. Financial consultancy services are particularly important in these kind of transactions as consultants can assist their clients with strategy planning and other professional services. The financial consultancy market has been growing rapidly in recent years driven by factors including rising prosperous M&A and financing activities, strong government support in terms of regulating policies and measures, enhanced participation of more parties and growing awareness of the importance of financial consultancy by downstream enterprises. Based on expert interviews and primary market research conducted by Frost & Sullivan, it is estimated that, from 2013 to 2017, the overall financial consultancy market in China increased from RMB136.9 billion to RMB257.2 billion at a compound annual growth rate, or CAGR, of 17.1%; and looking forward, it is forecasted that the economy in China will maintain a steady growth momentum over the next 5 years, and by 2022 the financial consultancy market is expected to reach RMB506.0 billion, at a CAGR of 14.2%.
    Page 48
    Page 17

    C
    Underpinned by the robust growth of the capital market in the PRC in recent years, the total number of listed companies in the PRC witnessed a steady growth from 2,489 in 2013 to 3,485 in 2017, representing a CAGR of 8.8% from 2013 to 2017. In addition, the number of listed companies on the Shanghai Stock Exchange (SSE) and Shenzhen Stock Exchange (SZSE) increased at a positive CAGR of 10.0% and 8.0% from 2013 to 2017 respectively. From 2012 to 2013, the PRC authorities prohibited IPOs resulting in zero newly listed companies occurring in 2013. From 2014 onward, the government re-approved IPO applications and therefore the total number of newly listed companies in the PRC rapidly increased at a CAGR of 51.7% from 2014 to 2017.
    Page 49
    Page 7-8

     4

Address: Room 3803, Dachong International Centre, 39 Tonggu Road, Nanshan district, Shenzhen, China

Tel: (+86) 0755-8695-0818

    D

        The expansion of the capital market and demand for fund

        raising is highlighted by the growth of listed companies.

        According to the market data provided by the Hong Kong

        Exchanges and Clearing (HKEx), the total number of listed

        companies in Hong Kong increased from 1,643 in 2013 to

        2,118 in 2017, representing a CAGR of approximately 6.6%. In
        addition, the number of newly listed companies in Hong Kong saw an overall growth from 110 in 2013 to 174 in 2017 at a CAGR of
        approximately 12.2% from 2013 to 2017. The growing number of listed companies in Hong Kong underpinned the demand for IPO consulting
        services as listed companies require consulting services in order to comply with the listing requirements specified by the HKEx.

    Pages 49-50
    Pages 9-10

    E
    Based on the market data provided by the Nasdaq Stock Market and World Federation of Exchange, from 2014 to 2017, the total number of existing listed companies on the NYSE and Nasdaq slightly decreased, primarily due to stringent listing regulations and increasing M&A activities in the US capital markets in recent years; from 2014 to 2017, the total number of newly listed companies on the NYSE and Nasdaq increased from 290 in 2014 to 317 in 2017, representing a CAGR of 3.0%; and as of September 11, 2018, there were 153 Chinese companies listed on the NYSE or Nasdaq.
    Page 50
    Page 12-14

    F
    The improving economy of the PRC has been directly driven by the robust capital market in recent years. As a result, the demand for up-to-date financial information on the internet has grown rapidly. In general, financial news media providers offer financial analysis and insight for investors. Online commercial advertisements provide streams of income for financial news media providers. Based on expert interviews and primary market research conducted by Frost and Sullivan, the total revenue of financial news media providers increased from RMB3.5 billion in 2013 to RMB6.2 billion in 2017, with a CAGR of 15.2% from 2013 to 2017; and with the continuous expansion of capital markets in the PRC and Hong Kong, the demand for such services are expected to grow; therefore, the market size by revenue of the financial news media industry is expected to grow at a CAGR of 17.1% from 2018 to 2022.
    Page 51
    Page 18

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Address: Room 3803, Dachong International Centre, 39 Tonggu Road, Nanshan district, Shenzhen, China

Tel: (+86) 0755-8695-0818

    G
    Underpinned by the strong economic growth and rising disposable income per capital in China, the demand for financial training and education in the PRC has been increasing. According to the Guiding Opinions of the State Council on Actively Advancing the “Internet plus” Action by the State Council of the PRC, the government has been promoting the synergy between the internet and financial training and education. Based on expert interviews and primary research conducted by Frost & Sullivan, the financial training and education market by number of students in China has been growing from 5.4 million in 2013 to 9.5 million in 2017, at a CAGR of 15.4%.
    Page 51
    Page 19

    H
    In order to encourage PRC companies to go public, governments from different municipalities and provinces have established various schemes and policies to subsidize these companies.
    Page 53
    Page 21

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Address: Room 3803, Dachong International Centre, 39 Tonggu Road, Nanshan district, Shenzhen, China

Tel: (+86) 0755-8695-0818

          PROSPECTUS SUMMARY

          The following summary is qualified in its entirety by, and should be read in conjunction with, the more detailed information and financial statements included elsewhere in this prospectus. In addition to this summary, we urge you to read the entire prospectus carefully, especially the risks of investing in our Ordinary Shares, discussed under “Risk Factors,” beginning on page 9 before deciding whether to buy our Ordinary Shares. This prospectus contains certain estimates and information from an industry report (“Frost & Sullivan Report”) commissioned by us and prepared by Frost & Sullivan Inc. (“Frost & Sullivan”), an independent market research firm, regarding our industries and our market positions in China, which have not been independently verified by us, the underwriters or any of their respective affiliates or advisers. The information in such sources may not be consistent with other information compiled in or outside of China.

          Overview

          Our Company

          Since November 2015, through our variable interest entity (“VIE”), Qianhai Asia Times (Shenzhen) International Financial Services Co., Ltd. (“Qianhai”), we have provided consulting services to small and medium-sized enterprises in mainland China. The focus of our consulting business has been to provide comprehensive consulting services designed to help small and medium-sized enterprises become public companies. We generated a total revenue of approximately US$104,000, US$3,635,000, and US$5,308,000 for the fiscal years ended July 31, 2016, 2017, and 2018, respectively. The revenues generated from consulting service were $49,253, $3,469,224, and $5,236,196 for the fiscal years ended July 31, 2016, 2017, and 2018, respectively. Before we are able to provide new clients with personalized going public consulting services, a one-time registration fee is charged to set up the clients’ accounts and profiles in our system. The revenue generated from the registration fee amounted to $54,921, $166,147, and $71,695 for the fiscal years ended July 31, 2016, 2017, and 2018, respectively.

          Beginning in August 2018, to complement and facilitate the growth of our consulting services, we launched AT Consulting Center to provide financial consulting services in Shenzhen, and in September, 2018, we acquired www.chinacnnm.com (“CNNM”), a news and media website focused on distributing financial news and information. Although upfront capital and human investments are required, we believe positive synergies can be generated by effectively integrating these two new business ventures with our existing consulting services, and we expect they will contribute to our growth in the long run.

          We have experienced substantial growth since our inception in 2015. Currently, all our consulting clients are located in mainland China, but our goal is to become an international consulting company with clients and offices throughout Asia.

          Industry Background

          The PRC economy has grown significantly since the PRC government introduced economic reforms in the late 1970s. This growth has accelerated since China entered the World Trade Organization in 2001. The China capital market has experienced rapid growth ever since the global financial crisis occurred in late 2008. PRC domestic companies are looking for opportunities in China as well as abroad to increase their presence in the global market. It is expected that financing activities such as mergers and acquisitions, and initial public offerings, will become more prosperous than before. Financial consultancy services are particularly important in these kind of transactions as consultants can assist their clients with strategy planning and other professional services. The financial consultancy market has been growing rapidly in recent years driven by factors including rising prosperous M&A and financing activities, strong government support in terms of regulating policies and measures, enhanced participation of more parties and growing awareness of the importance of financial consultancy by downstream enterprises. Based on expert interv