SecProbe.io

October 31, 2019
Guangjie Jin
Chief Executive Officer
Q&K International Group Limited
Suite 1607, Building A
No.596 Middle Longhua Road
Xuhui District, Shanghai, 200032
People's Republic of China
Re:Q&K International Group Limited
Amendment No. 1 to Registration Statement on Form F-1
Filed October 25, 2019
File No. 333-234112
Dear Mr. Jin:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our October 16, 2019 letter.
Form F-1 filed October 25, 2019
General
1.We note your response to prior comment 2 that the price adjustments are excluded from
the average monthly rental or the average monthly rental before discount for rental
prepayments.  We further note the definitions of average monthly rental and average
monthly rental before discount for rental prepayments on page 8 as well as your disclosure
regarding your marketing expenses and promotion costs on pages 99 and 100.  Please
confirm to us that the average monthly rental and average monthly rental before discount
for rental prepayments amounts on pages 17 and 96 reflect all promotion costs or revise

 FirstName LastNameGuangjie Jin
 Comapany NameQ&K International Group Limited
 October 31, 2019 Page 2
 FirstName LastName
Guangjie Jin
Q&K International Group Limited
October 31, 2019
Page 2
accordingly.  In addition, please tell us the nature of the promotion costs that are included
in the selling and marketing expenses described on page 100.
            You may contact Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Maryse Mills-Apenteng at 202-551-3457 or Jennifer Gowetski at 202-551-3401 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Shuang Zhao, Esq.