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Blue
Hat Interactive Entertainment Technology

7th
Floor, Building C, No. 1010 Anling Road

Huli
District, Xiamen, China 361009

86-592-228-0081

                                   August
8, 2024

Via Edgar

Stephany Yang/Melissa Gilmore

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Blue Hat Interactive Entertainment Technology

    Form 20-F for the Fiscal Year Ended December 31, 2023

    Filed April 30, 2024

    File No. 001-39001

Dear Ms. Yang and Ms. Gilmore:

We have set forth below responses to the comments of the staff (the “Staff”)
of the Securities and Exchange Commission (the “SEC”) contained in its letter of July 25, 2024 with respect to the Annual
Report on Form 20-F (the “20-F”, File No. 001-39001) filed with the SEC on April 30, 2024 by Blue Hat Interactive Entertainment
Technology (the “Company”). For your convenience, the texts of the Staff’s comments are set forth below followed by
the Company’s responses in bold. Please note that all references in the responses refer to the relevant revisions in the Amendment
No. 1 to the Annual Report (the “20-F/A”) filed with the SEC concurrently with the submission of this letter.

Form 20-F for the Fiscal Year Ended December 31,
2023

Part I

Item 3. Key Information, Page 1

 1. At the onset of Part I, please disclose prominently that you are
not a Chinese operating company but a Cayman Islands holding company with operations conducted by your subsidiaries based in China. In
addition, please provide early in the Key Information section a diagram of your corporate structure.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on page 1 of the 20-F/A.

 2. At the onset of Part I, please provide prominent disclosure about
the legal and operational risks associated with having the majority of the company’s operations in China. Your disclosure should
make clear whether these risks could result in a material change in your operations and/or the value of the securities or could significantly
limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to
significantly decline or be worthless. Your disclosure should address how recent statements and regulatory actions by China’s government,
such as those related to data security or anti-monopoly concerns, have or may impact the company’s ability to conduct its business,
accept foreign investments, or list on a U.S. or other foreign exchange. Please disclose the location of your auditor’s headquarters
and whether and how the Holding Foreign Companies Accountable Act, as amended by the Consolidated Appropriations Act 2023, and related
regulations will affect your company.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on pages 3-5 of the 20-F/A.

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 3. At the onset of Part I, please clearly disclose how you will refer
to the holding company and subsidiaries when providing the disclosure throughout the document so that it is clear to investors which entity
the disclosure is referencing and which subsidiaries or entities are conducting the business operations. Refrain from using terms such
as “we” or “our” when describing activities or functions of a subsidiary or other entity. For example, disclose,
if true, that your subsidiaries and/or other entities conduct operations in China, that the other entity is consolidated for accounting
purposes but is not an entity in which you own equity, and that the holding company does not conduct operations. Disclose clearly the
entity (including the domicile) in which investors are purchasing an interest.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on page 1 of the 20-F/A. In addition, the Company respectfully pointed out to the Staff
that the Company has clearly disclosed its reference to the subsidiaries on the cover page of the 20-F, which remain unchanged in the
20-F/A filed herein.

 4. At the onset of Item 3, please disclose the risks that your corporate
structure and having the majority of the company’s operations in China poses to investors. In particular, describe the significant
regulatory, liquidity, and enforcement risks with cross-references to the more detailed discussion of these risks in Risk Factors. For
example, specifically discuss risks arising from the legal system in China, including risks and uncertainties regarding the enforcement
of laws and that rules and regulations in China can change quickly with little advance notice; and the risk that the Chinese government
may intervene or influence your operations at any time, or may exert more control over offerings conducted overseas and/or foreign investment
in China-based issuers, which could result in
a material change in your operations and/or the value of the securities you are registering for sale. Acknowledge any risks that any actions
by the Chinese government to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in
China-based issuers could significantly limit or completely hinder your ability to offer or continue to offer securities to investors
and cause the value of such securities to significantly decline or be worthless.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on pages 3-4 of the 20-F/A.

 5. At the onset of Item 3, please disclose each permission or approval that you or your subsidiaries
are required to obtain from Chinese authorities to operate your business and to offer the securities being registered to foreign investors.
State whether you or your subsidiaries are covered by permissions requirements from the China Securities Regulatory Commission (CSRC),
Cyberspace Administration of China (CAC) or any other governmental agency that is required to approve the operations, and state affirmatively
whether you have received all requisite permissions or approvals and whether any permissions or approvals have been denied. Please also
describe the consequences to you and your investors if you or your subsidiaries: (i) do not receive or maintain such permissions or approvals,
(ii) inadvertently conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations
change and you are required to obtain such permissions or approvals in the future.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on pages 2-3 of the 20-F/A.

 6. At the onset of Item 3, please provide a clear description of how cash is transferred through your organization.
Disclose your intentions to distribute earnings. Quantify any cash flows and transfers of other assets by type that have occurred between
the holding company and the subsidiaries, and direction of transfer. Quantify any dividends or distributions that a subsidiary has made
to the holding company and which entity made such transfer, and their tax consequences. Similarly quantify dividends or distributions
made to U.S. investors, the source, and their tax consequences. Your disclosure should make clear if no transfers, dividends, or distributions
have been made to date. Describe any restrictions on foreign exchange and your ability to transfer cash between entities, across borders,
and to U.S. investors. Describe any restrictions and limitations on your ability to distribute earnings from the company, including your
subsidiaries, to the parent company and U.S. investors.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on pages 3-4 of the 20-F/A.

D. Risk
Factors

You may experience difficulties in effecting service
of legal process..., page 22

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 7. We note your disclosure that all your senior employees reside within China for a significant portion of
the time and most are PRC residents. In future filings, please identify any directors, officers, or members of senior management located
in the PRC/Hong Kong. Additionally, please include a separate “Enforceability” section that addresses whether or not investors
may bring actions under the civil liability provisions of the U.S. federal securities laws against you, your officers or directors who
are residents of a foreign country, and whether investors may enforce these civil liability provisions when your assets, officers, and
directors are located outside of the United States.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on pages 5-6 of the 20-F/A.

Item 5. Operating and Financial Review and Prospects

B. Liquidity and capital resources, page 69

 8. We note your disclosure that you believe your revenues and operations will continue to grow and your current
working capital is sufficient to support your operations for the next twelve months. We also note your disclosure on page F-13 regarding
going concern. Please revise your disclosure to remove the inconsistencies. Additionally highlight that your auditor has expressed substantial
doubt about your ability to continue as a going concern.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on page 75 of the 20-F/A.

Item 15. Controls and Procedures

Management’s Annual Report on Internal Control
over Financial Reporting..., page 94

 9. We note that material weaknesses remained as of December 31, 2023; however, you do not include a statement
as to whether your internal control over financial reporting is effective as required by Item 308(a)(3) of Regulation S-K. Please revise
to include a statement as to whether ICFR is effective.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on page 101 of the 20-F/A.

Changes in Internal Control over Financial Reporting,
page 95

 10. Please revise your disclosures on page 96 that you were not required to perform an evaluation of your
internal control over financial reporting as of December 31, 2023 and you did not undertake a comprehensive assessment of your internal
control over financial reporting, which are inconsistent with your disclosure in the Management’s Annual Report on Internal Control
over Financial Reporting on page 94.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on page 101 of the 20-F/A.

Item 16K.
Cybersecurity, page 98

 11. We note your disclosure that the Item 16K Cybersecurity is not applicable. Please revise to provide the
cybersecurity disclosure required by Item 16K of Form 20-F.

 Response: In ressponse to the Staff’s
comment, the Company has added relevant disclosure under Item 16K. Cybersecurity on page 104 of the 20-F/A.

Notes to Consolidated Financial Statements, page
F-9

 12. We note your disclosure on page F-7 that you recorded impairment
of inventory for $12,600,000 during the year ended December 31, 2023. On page F-25, we note
your disclosure that allowance for obsolete inventory was nil as of December 31, 2023. Please explain to us and disclose what the amount
of the inventory impairment related to.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on page F-25 of the 20-F/A under Note 6 – Inventories, Net.

23. Segment Information and Revenue Analysis, page
F-37

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 13. We note your disclosures that the Company has three reporting segments and considers itself to be operating
within one reportable segment. Please revise the disclosures to remove the inconsistencies as it appears you have three reportable segments
as presented. Please also remove the disclosure that the Company’s revenue and net income are substantially derived from interactive
toys and mobile games.

Response: In response to the Staff’s
comment, has revised its disclosure on page F-37 of the 20-F/A under Note 23 – Segment Information and Revenue Analysis.

Exhibits 12.1 and 12.2 Section 302 Certification,
page X-12

 14. Your certifications do not include the language referring to internal control over financial reporting
that should appear in the introductory sentence of paragraph 4 of the Section 302 certifications. Please revise both of Section 302 certifications
to include certifications conforming to the language as set forth in Item 19 of Form 20-F.

Response: In response to the Staff’s
comment, the Company has revised both Section 302 certifications and include them as exhibits to the 20-F/A.

General

 15. Please disclose whether and how your business segments, products, lines of service, projects, or operations
are materially impacted by supply chain disruptions especially in light of the effectiveness of the Uyghur Forced Labor Prevention Act
(UFLPA). For example, discuss whether you have or expect to:

●	Suspend
the production, purchase, sale or maintenance of certain items due to a lack of raw materials, parts, or equipment; inventory shortages;
closed factories or stores; reduced headcount; or delayed projects;

●	Experience
labor shortages that impact your business;

●	Experience
cybersecurity attacks in your supply chain;

●	Experience
higher costs due to constrained capacity or increased commodity prices or challenges sourcing materials;

●	Experience
surges or declines in consumer demand for which you are unable to adequately adjust your supply;

●	Be
unable to supply products at competitive prices or at all; or

●	Be
exposed to supply chain risk in light of the effectiveness of the UFLPA.

Explain
whether and how you have undertaken efforts to mitigate the impact and where possible quantify the impact to your business.

Response: The Company respectfully pointed
out to the Staff that the Company, its subsidiaries, and the pre-existing VIEs have no connection with the Xinjiang Uygur Autonomous Region
(the “Xinjiang UAR”) in their operation or manufacture, nor do the Company, its subsidiaries and the pre-existing VIEs have
any plans to expand their business to the Xinjiang UAR. Therefore, the effectiveness of the UFLPA bears no relevance to the Company and
its business.

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 16. You disclose your website as http://www.irbluehatgroup.com on page 40.
This does not appear to be a working website. Please revise.

Response: In response to the Staff’s
comment, the Company clarified that its website is http://ir.bluehatgroup.com, the site without “www” in the front and the
Company has made the update on pages 46 and 103 of the 20-F/A.

We thank you for the review and
the comments. Should you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please
call or email our legal counsel, Elizabeth F. Chen at (212) 326-0199, echen@pryorcashman.com. Thank you for your time and attention to
this filing.

Sincerely,

/s/ Xiaodong Chen

Xiaodong Chen

Chief Executive Officer and President
 (Principal Executive Officer)

    cc:
    Elizabeth F. Chen, Pryor Cashman LLP

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