SecProbe.io

CORRESP
 1
 filename1.htm

 Blue Hat Interactive Entertainment Technology

 7th Floor, Building C

 No. 1010 Anling Road

 Huli District, Xiamen, China 361009

 86-592-228-0081

 February 13, 2026

 VIA EDGAR CORRESPONDENCE

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office
of Trade & Services

 100 F Street, N.E. Washington, D.C. 20549

 Re: Blue Hat Interactive Entertainment Technology
Registration Statement on Form F-1 (the "Registration Statement")

 Filed February 9, 2026 (Registration No.:
333-293313)

 Withdrawal of Acceleration Request

 Ladies and Gentlemen:

 Reference is made to our letter,
filed as correspondence via EDGAR on February 12, 2026, in which we, Blue Hat Interactive Entertainment Technology (the "Company")
requested the acceleration of the effective date of the above-referenced Registration Statement for 5:00 p.m., Eastern Time, on February
12, 2026, or as soon as possible thereafter, in accordance with Rule 461 under the Securities Act of 1933, as amended. We are no longer
requesting that such Registration Statement be declared effective at this time and we hereby formally withdraw our request for acceleration
of the effective date.

 If you have any questions, please
do not hesitate to contact Elizabeth F. Chen of Pryor Cashman LLP, outside counsel to the Company, at echen@pryorcashman.com (Tel: 212-326-0199).

 Very truly yours,

 Blue Hat Interactive Entertainment Technology

 By:
 /s/
 Xiaodong Chen

 Xiaodong Chen

 Chief Executive Officer

 cc: Elizabeth F. Chen, Esq.
 Pryor Cashman LLP

CORRESP
 1
 filename1.htm

 MAXIM GROUP LLC

 300 Park Avenue, 16th Floor

 New York, New York 10022

 VIA EDGAR

 February 13, 2026

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn:

 Kate Beukenkamp
 Nicholas Nalbantian

 Re:
 Blue Hat Interactive Entertainment Technology (CIK No. 0001759136)

 Request for Acceleration

 Registration Statement Form F-1 (File No. 333- 293313)

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and Regulations
of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, Maxim Group LLC, as representative of the
underwriters, hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it will become
effective at 9:00 a.m., Eastern Time on February 17, 2026, or as soon thereafter as practicable.

 Pursuant to Rule 460 under the Act, we wish to advise
you that we have distributed as many copies of the preliminary prospectus dated February 9, 2026, to selected dealers, institutions and
others as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

 The undersigned confirms that it has complied and
will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied or will comply
with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced issue.

 Very truly yours,

 Maxim Group LLC

 By:
 /s/ Ritesh M. Veera

 Name:
 Ritesh M. Veera

 Title:
 Co-Head of Investment Banking

CORRESP
 1
 filename1.htm

 Blue Hat Interactive Entertainment Technology

 7th Floor, Building C

 No. 1010 Anling Road

 Huli District, Xiamen, China 361009

 February 13, 2026

 Via EDGAR

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Attn:

 Kate Beukenkamp
 Nicholas Nalbantian

 Re:
 Blue Hat Interactive Entertainment Technology

 Registration Statement on Form F-1

 Filed on February 9, 2026

 File No. 333-293313

 Ladies and Gentlemen:

 In accordance with Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended, Blue Hat Interactive Entertainment Technology (the
"Company") hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1 be accelerated
and that the Registration Statement become effective at 9:00 a.m., Eastern Time, on Tuesday, February 17, 2026, or as soon thereafter
as practicable.

 The Company acknowledges that:
(1) should the Securities and Exchange Commission (the "Commission") or 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; (2) 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 (3) 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 questions, please
do not hesitate to contact Elizabeth Fei Chen of Pryor Cashman LLP, outside counsel to the Company, at echen@pryorcashman.com (Tel: 212-326-0199).

 Very truly yours,

 Blue Hat Interactive Entertainment Technology

 By:
 /s/ Xiaodong Chen

 Name:
 Xiaodong Chen

 Title:
 Chief Executive Officer

 Cc: Elizabeth Fei Chen, Esq.

CORRESP
 1
 filename1.htm

 MAXIM GROUP LLC

 300 Park Avenue, 16th Floor

 New York, New York 10022

 VIA EDGAR

 February 13, 2026

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn:

 Kate Beukenkamp

 Nicholas Nalbantian

 Re:
 Blue Hat Interactive Entertainment Technology (CIK No. 0001759136)

 Withdrawal of Acceleration Request

 Registration Statement on Form F-1 (File No. 333- 293313)

 Ladies and Gentlemen:

 Reference is made to our letter, filed as correspondence
with the U.S. Securities and Exchange Commission via EDGAR on February 12, 2026, in which we joined Blue Hat Interactive Entertainment
Technology in requesting the acceleration of the effective date of the above-captioned Registration Statement for February 12, 2026, at
5:00 p.m. Eastern Time, or as soon as practicable thereafter, in accordance with Rule 461 under the Securities Act of 1933, as amended.
Blue Hat Interactive Entertainment Technology is no longer requesting that such Registration Statement be declared effective at such date
and time, and we hereby formally withdraw our request for acceleration of the effective date of the above-captioned Registration Statement.

 Very truly yours,

 Maxim Group LLC

 By:
 /s/ Ritesh M. Veera

 Name:
 Ritesh M. Veera

 Title:
 Co-Head of Investment Banking

CORRESP
 1
 filename1.htm

 Blue Hat Interactive
Entertainment Technology

 7th Floor, Building C

 No. 1010 Anling Road

 Huli District, Xiamen,
China 361009

 February 12, 2026

 Via EDGAR

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Attn:

 Kate Beukenkamp

 Nicholas Nalbantian

 Re:
 Blue
 Hat Interactive Entertainment Technology

 Registration
 Statement on Form F-1

 Filed
 on February 9, 2026

 File
 No. 333-293313

 Ladies and Gentlemen:

 In accordance with Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended, Blue Hat Interactive Entertainment Technology (the
"Company") hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1 be accelerated
and that the Registration Statement become effective at 5:00 p.m., Eastern Time, on Thursday, February 12, 2026, or as soon thereafter
as practicable.

 The Company acknowledges that:
(1) should the Securities and Exchange Commission (the "Commission") or 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; (2) 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 (3) 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 questions, please
do not hesitate to contact Elizabeth Fei Chen of Pryor Cashman LLP, outside counsel to the Company, at echen@pryorcashman.com (Tel: 212-326-0199).

 Very truly yours,

 Blue Hat Interactive Entertainment Technology

 By:
 /s/ Xiaodong Chen

 Name:
 Xiaodong Chen

 Title:
 Chief Executive Officer

 Cc: Elizabeth Fei Chen, Esq.

CORRESP
 1
 filename1.htm

 MAXIM GROUP LLC

 300 Park Avenue, 16th Floor

 New York, New York 10022

 VIA EDGAR

 February 12, 2026

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn:

 Kate Beukenkamp
 Nicholas Nalbantian

 Re:
 Blue Hat Interactive Entertainment Technology (CIK No. 0001759136)

 Request for Acceleration

 Registration Statement Form F-1 (File No. 333- 293313)

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and Regulations
of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, Maxim Group LLC, as representative of the
underwriters, hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it will become
effective at 5:00 p.m., Eastern Time on February 12, 2026, or as soon thereafter as practicable.

 Pursuant to Rule 460 under the Act, we wish to advise
you that we have distributed as many copies of the preliminary prospectus dated February 9, 2026, to selected dealers, institutions and
others as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

 The undersigned confirms that it has complied and
will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied or will comply
with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced issue.

 Very truly yours,

 Maxim Group LLC

 By:
 /s/ Ritesh M. Veera

 Name: Ritesh M. Veera

 Title: Co-Head of Investment Banking

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 26, 2026

Xiaodong Chen
Chief Executive Officer
Blue Hat Interactive Entertainment Technology
7th Floor, Building C
No. 1010 Anling Road
Huli District, Xiamen, China 361009

 Re: Blue Hat Interactive Entertainment Technology
 Draft Registration Statement on Form F-1
 Submitted January 22, 2026
 CIK No. 0001759136
Dear Xiaodong Chen:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement and
non-public draft
submission on EDGAR at least two business days prior to the requested effective
date and time.
Please refer to Rules 460 and 461 regarding requests for acceleration. We
remind you that the
company and its management are responsible for the accuracy and adequacy of
their disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

 Please contact Kate Beukenkamp at 202-551-3861 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Elizabeth Chen
</TEXT>
</DOCUMENT>

August 14, 2024
Xiaodong (Sean) Chen
Chief Executive Officer
Blue Hat Interactive Entertainment Technology
7th Floor, Building C, No. 1010 Anling Road Huli District
Xiamen, China 361009
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 Xiaodong (Sean) Chen:
            We have completed our review of your filing. We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

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.

    1

 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

    2

 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

    3

 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.

    4

 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

5

July 25, 2024
Xiaodong (Sean) Chen
Chief Executive Officer
Blue Hat Interactive Entertainment Technology
7th Floor, Building C, No. 1010 Anling Road Huli District
Xiamen, China 361009
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 Xiaodong (Sean) Chen:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.

July 25, 2024
Page 2
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.
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.
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.
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.
At the onset of Item 3, please disclose each permission or approval that you or your 5.

July 25, 2024
Page 3
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.
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.
D. Risk Factors
You may experience difficulties in effecting service of legal process..., page 22
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.
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.
Item 15. Controls and Procedures

July 25, 2024
Page 4
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.
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.
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.
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.
23. Segment Information and Revenue Analysis, page F-37
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.
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.
General
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;15.

July 25, 2024
Page 5
• 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.
16.You disclose your website as http://www.irbluehatgroup.com on page 40. This does not
appear to be a working website. Please revise.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Stephany Yang at 202-551-3167 or Melissa Gilmore at 202-551-3777 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

Blue Hat Interactive Entertainment Technology

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

Huli District, Xiamen, China 361009

86-592-228-0081

January 25, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade and Services

100 F Street, NE

Washington, D.C. 20549

Attention: Gregory Herbers and Evan Ewing

    Re:
    Blue Hat Interactive Entertainment Technology

    Registration Statement on Form F-3, as amended

    File No. 333-274893

Gentlemen:

	Blue Hat Interactive Entertainment
Technology (the “Company”) hereby requests that the above-captioned registration statement (the “Registration Statement”)
be declared effective at 4:00 p.m., Eastern Time on Friday, January 26, 2024, or as soon thereafter as may be practicable.

	We acknowledge that a declaration
by the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, that the
Registration Statement is effective does not foreclose the Commission from taking any action with respect to the Registration Statement.
We further acknowledge that such a declaration of effectiveness does not relieve the Company from our full responsibility for the adequacy
and accuracy of the disclosure in the Registration Statement. We understand that we may not assert staff comments to the Registration
Statement or the declaration of effectiveness by the Commission 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 questions,
please do not hesitate to contact the undersigned at sean@bluehatgroup.net or Elizabeth F. Chen of Pryor Cashman LLP, outside counsel
to the Company, at echen@pryorcashman.com (Tel: 212-326-0199).

    Very truly yours,

    /s/ Xiaodong Chen

    Xiaodong Chen

    Chief Executive Officer

cc:	Elizabeth Fei Chen, Esq.

CORRESP
1
filename1.htm

Blue Hat Interactive Entertainment Technology

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

Huli District, Xiamen, China 361009

86-592-228-0081

January
19, 2024

Via Edgar

Gregory Herbers/Evan Ewing

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

    Amendment No. 1 to Registration Statement on Form F-3

    Filed December 29, 2023

    File No. 333-274893

Dear Mr. Herbers and Mr. Ewing:

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 January 9, 2024 with respect to the Amendment No.1 to the Registration Statement on Form F-3 (File No. 333-274893) filed
with the SEC on December 29, 2023 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. 2 to the Registration Statement on Form F-3 (the “F-3/A”)
filed with the SEC concurrently with the submission of this letter.

Amendment No. 1 to Form F-3 filed December 29, 2023

Prospectus Summary, page 1

1. We note your response to prior comment 4 and reissue in full.

Response: In response to the Staff’s comment, the Company
has added a subsection of “Summary of Risk Factors” on pages 8-9 of the F-3/A.

Risk Factors, page 9

 2. We note your response to prior comment 7. Given the Chinese government’s
significant oversight and discretion over the conduct and operations of your business, please revise to describe any material impact that
intervention, influence, or control by the Chinese government has or may have on your business or on the value of your securities. Highlight
separately the risk that the Chinese government may intervene or influence your operations at any time, which could result in a material
change in your operations and/or the value of your securities. Also, given recent statements by the Chinese government indicating an intent
to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based issuers,
acknowledge the risk that any such action 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. We remind you that, pursuant to federal
securities rules, the term “control” (including the terms “controlling,” “controlled by,” and “under
common control with”) means “the possession, direct or indirect, of the power to direct or cause the direction of the management
and policies of a person, whether through the ownership of voting securities, by contract, or otherwise.”

Response: In response to the Staff’s comment, the Company
has added certain risks factors related to doing business in China on pages 11-14 of the F-3/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

United States securities and exchange commission logo
January 9, 2024
Xiaodong Chen
Chief Executive Officer
Blue Hat Interactive Entertainment Technology
7th Floor, Building C, No. 1010 Anling Road
Huli District, Xiamen, China 361009
Re:Blue Hat Interactive Entertainment Technology
Amendment No. 1 to Registration Statement on Form F-3
Filed December 29, 2023
File No. 333-274893
Dear Xiaodong Chen:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our November 1, 2023 letter.
Amendment No. 1 to Form F-3 filed December 29, 2023
Prospectus Summary, page 1
1.We note your response to prior comment 4 and reissue in full.
Risk Factors, page 9
2.We note your response to prior comment 7. Given the Chinese government’s significant
oversight and discretion over the conduct and operations of your business, please revise to
describe any material impact that intervention, influence, or control by the Chinese
government has or may have on your business or on the value of your securities. Highlight
separately the risk that the Chinese government may intervene or influence your
operations at any time, which could result in a material change in your operations and/or
the value of your securities. Also, given recent statements by the Chinese government
indicating an intent to exert more oversight and control over offerings that are conducted

 FirstName LastNameXiaodong Chen
 Comapany NameBlue Hat Interactive Entertainment Technology
 January 9, 2024 Page 2
 FirstName LastName
Xiaodong Chen
Blue Hat Interactive Entertainment Technology
January 9, 2024
Page 2
overseas and/or foreign investment in China-based issuers, acknowledge the risk that any
such action 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. We remind you that, pursuant to federal securities rules, the term
“control” (including the terms “controlling,” “controlled by,” and “under common control
with”) means “the possession, direct or indirect, of the power to direct or cause the
direction of the management and policies of a person, whether through the ownership of
voting securities, by contract, or otherwise.”
            Please contact Gregory Herbers at 202-551-8028 or Evan Ewing at 202-551-5920 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Elizabeth Fei Chen

CORRESP
1
filename1.htm

Blue Hat Interactive Entertainment Technology

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

Huli District, Xiamen, China 361009

86-592-228-0081

    December 29, 2023

Via Edgar

Gregory Herbers/Evan Ewing

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

    Registration Statement on Form F-3

    Filed October 6, 2023

    File No. 333-274893

Dear Mr. Herbers and Mr. Ewing:

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 November 1, 2023 with respect to the Registration Statement on Form F-3 (File No. 333-274893) filed
with the SEC on October 6, 2023 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 Registration Statement on Form F-3
(the “F-3/A No. 1”) filed with the SEC concurrently with the submission of this letter.

Registration Statement on Form F-3

Cover Page

 1. Please disclose prominently on the prospectus cover page that you are not a Chinese operating company
but a Cayman Islands holding company with operations conducted by your subsidiaries based in China and that this structure involves
unique risks to investors. Provide a cross-reference to your detailed discussion of risks facing the company and the offering as
a result of this structure.

Response: In response to the Staff’s comment, the Company has made updates
on the cover page of the F-3/A No.1.

 2. Clearly disclose how you will refer to the holding company,
subsidiaries, and other entities 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 made revisions
on the cover page, pages 1-3 and page 5 of F-3/A No.1.

 3. Provide a description of how cash is transferred through your organization and disclose your intentions
to distribute earnings or settle amounts owed under applicable agreements. State whether any transfers, dividends, or distributions
have been made to date between the holding company, its subsidiaries, and consolidated entities, or to investors, and quantify
the amounts where applicable.

Response: In response to the Staff’s
comment, the Company has added relevant disclosure on the cover page of the F-3/A No.1.

Prospectus Summary, page
1

 4. In your summary of risk factors, disclose the risks that
your corporate structure and being based in or 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 the prospectus. 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 pointed out to the Staff that a summary of risk factors and a complete list of risk factors have been
disclosed in the Company’s annual report on 20-F, which has been incorporated by reference into the F-3/A No.1.

 5. 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 your or your subsidiaries’ 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 added a list of permissions and approvals and relevant disclosure on pages 6 and pages 9-10 of the F-3/A
No.1.

 6. Provide a clear description of how cash is transferred through
your organization. Disclose your intentions to distribute earnings or settle amounts owed under your operating structure. Quantify
any cash flows and transfers of other assets by type that have occurred between the holding company and its 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 as well as the ability to settle amounts owed under applicable agreements.

Response: In response to the Staff’s
comment, the Company has added relevant disclosure on pages 6 and 7 of the F-3/A No.1.

Risk Factors, page 8

 7. Given the significant oversight and discretion of the government
of the People’s Republic of China (PRC) over the operations of your business, please describe any material impact that intervention
or control by the PRC government has or may have on your business or on the value of your securities. We remind you that, pursuant
to federal securities rules, the term “control” (including the terms “controlling,” “controlled by,”
and “under common control with”) means “the possession, direct or indirect, of the power to direct or cause the
direction of the management and policies of a person, whether through the ownership of voting securities, by contract, or otherwise.”

Response: In response to the Staff’s
comment, the Company has added relevant disclosure on pages 9-10 of the F-3/A No.1.

 8. In light of recent events indicating greater oversight by the Cyberspace Administration of China
(CAC) over data security, particularly for companies seeking to list on a foreign exchange, please revise your disclosure to explain
how this oversight impacts your business and your offering and to what extent you believe that you are compliant with the regulations
or policies that have been issued by the CAC to date.

Response: In response to the Staff’s
comment, the Company has added relevant disclosure on pages 9-10 of the F-3/A No.1.

Incorporation of Certain Information by Reference, page 42

 9. Please revise to provide the disclosure required by Item 6(b) of Form F-3.

Response: The Company has added such disclosure
to the F-3/A No.1 on page 45.

Exhibits

10. Please file the auditor’s consent.

Response:
The Company has filed the auditor’s consent as an exhibit to the F-3/A No.1.

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

United States securities and exchange commission logo
November 1, 2023
Xiaodong Chen
Chief Executive Officer
Blue Hat Interactive Entertainment Technology
7th Floor, Building C, No. 1010 Anling Road
Huli District, Xiamen, China 361009
Re:Blue Hat Interactive Entertainment Technology
Registration Statement on Form F-3
Filed October 6, 2023
File No. 333-274893
Dear Xiaodong Chen:
            We have conducted a limited review of your registration statement and have the
following comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Registration Statement on Form F-3
Cover Page
1.Please disclose prominently on the prospectus cover page that you are not a Chinese
operating company but a Cayman Islands holding company with operations conducted by
your subsidiaries based in China and that this structure involves unique risks to
investors. Provide a cross-reference to your detailed discussion of risks facing the
company and the offering as a result of this structure.
2.Clearly disclose how you will refer to the holding company, subsidiaries, and other
entities 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

 FirstName LastNameXiaodong Chen
 Comapany NameBlue Hat Interactive Entertainment Technology
 November 1, 2023 Page 2
 FirstName LastNameXiaodong Chen
Blue Hat Interactive Entertainment Technology
November 1, 2023
Page 2
equity, and that the holding company does not conduct operations. Disclose clearly the
entity (including the domicile) in which investors are purchasing an interest.
3.Provide a description of how cash is transferred through your organization and disclose
your intentions to distribute earnings or settle amounts owed under applicable agreements.
State whether any transfers, dividends, or distributions have been made to date between
the holding company, its subsidiaries, and consolidated entities, or to investors, and
quantify the amounts where applicable.
Prospectus Summary, page 1
4.In your summary of risk factors, disclose the risks that your corporate structure and being
based in or 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 the prospectus. 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.
5.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 your or your subsidiaries’ 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.
6.Provide a clear description of how cash is transferred through your organization. Disclose
your intentions to distribute earnings or settle amounts owed under your operating
structure. Quantify any cash flows and transfers of other assets by type that have occurred
between the holding company and its subsidiaries, and direction of transfer. Quantify any
dividends or distributions that a subsidiary has made to the holding company and which

 FirstName LastNameXiaodong Chen
 Comapany NameBlue Hat Interactive Entertainment Technology
 November 1, 2023 Page 3
 FirstName LastNameXiaodong Chen
Blue Hat Interactive Entertainment Technology
November 1, 2023
Page 3
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 as well as the ability to settle
amounts owed under applicable agreements.
Risk Factors, page 8
7.Given the significant oversight and discretion of the government of the People’s Republic
of China (PRC) over the operations of your business, please describe any material impact
that intervention or control by the PRC government has or may have on your business or
on the value of your securities.  We remind you that, pursuant to federal securities rules,
the term “control” (including the terms “controlling,” “controlled by,” and “under
common control with”) means “the possession, direct or indirect, of the power to direct or
cause the direction of the management and policies of a person, whether through the
ownership of voting securities, by contract, or otherwise.”
8.In light of recent events indicating greater oversight by the Cyberspace Administration of
China (CAC) over data security, particularly for companies seeking to list on a foreign
exchange, please revise your disclosure to explain how this oversight impacts your
business and your offering and to what extent you believe that you are compliant with the
regulations or policies that have been issued by the CAC to date.
Incorporation of Certain Information by Reference, page 42
9.Please revise to provide the disclosure required by Item 6(b) of Form F-3.
Exhibits
10.Please file the auditor's consent.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Gregory Herbers at 202-551-8028 or Evan Ewing at 202-551-5920 with
any questions.

 FirstName LastNameXiaodong Chen
 Comapany NameBlue Hat Interactive Entertainment Technology
 November 1, 2023 Page 4
 FirstName LastName
Xiaodong Chen
Blue Hat Interactive Entertainment Technology
November 1, 2023
Page 4
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Elizabeth Fei Chen

CORRESP
1
filename1.htm

June 25, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549-0405

Attention: Anne McConnell

    RE:
    Blue Hat Interactive Entertainment Technology

    Registration Statement on Form F-1

    File No. 333-257265

    Filed June 22, 2021

Ladies and Gentlemen:

	Blue Hat Interactive Entertainment
Technology (the “Company”) hereby requests that the above-captioned registration statement (the “Registration Statement”)
be declared effective at 9:00 A.M., Eastern Time on Tuesday, June 29, 2021, or as soon thereafter as may be practicable.

	We acknowledge that a declaration
by the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, that the
Registration Statement is effective does not foreclose the Commission from taking any action with respect to the Registration Statement.
We further acknowledge that such a declaration of effectiveness does not relieve the Company from our full responsibility for the adequacy
and accuracy of the disclosure in the Registration Statement. We understand that we may not assert staff comments to the Registration
Statement or the declaration of effectiveness by the Commission 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 questions,
please do not hesitate to contact the undersigned at sean@bluehatgroup.net or Elizabeth F. Chen of Pryor Cashman LLP, outside counsel
to the Company, at echen@pryorcashman.com (Tel: 212-326-0199).

    Very truly yours,

    /s/ Xiaodong Chen

    Xiaodong Chen

    Chief Executive Officer

cc:	Elizabeth Fei Chen, Esq.

United States securities and exchange commission logo
June 24, 2021
Xiaodong Chen
CEO
Blue Hat Interactive Entertainment Technology
7th Floor, Building C, No. 1010 Anling Road
Huli District, Xiamen, China 361009
Re:Blue Hat Interactive Entertainment Technology
Registration Statement on Form F-1
File No. 333-257265
Filed on June 22, 2021
Dear Mr. Chen:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Anne McConnell at 202-551-3709 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

May
4, 2021

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, NE

Washington,
D.C. 20549-0405

Attention:
Mindy Hooker

RE:  Blue
                                            Hat Interactive Entertainment Technology

    Registration
                                            Statement on Form F-1

    Filed
                                            April 21, 2021

    File
                                            No. 333-255391

Ladies
and Gentlemen:

	Blue
Hat Interactive Entertainment Technology (the “Company”) hereby requests that the above-captioned registration statement
(the “Registration Statement”) be declared effective at 4:00 P.M., Eastern Time on Thursday, May 6, 2021, or as soon thereafter
as may be practicable.

	We
acknowledge that a declaration by the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant
to delegated authority, that the Registration Statement is effective does not foreclose the Commission from taking any action with respect
to the Registration Statement. We further acknowledge that such a declaration of effectiveness does not relieve the Company from our
full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement. We understand that we may not assert
staff comments to the Registration Statement or the declaration of effectiveness by the Commission 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 questions, please do not hesitate to contact the undersigned at sean@bluehatgroup.net or Elizabeth F. Chen of Pryor Cashman
LLP, outside counsel to the Company, at echen@pryorcashman.com (Tel: 212-326-0199).

Very
truly yours,

/s/
Xiaodong Chen

Xiaodong
Chen

Chief
Executive Officer

cc:	Elizabeth
Fei Chen, Esq.

United States securities and exchange commission logo
April 26, 2021
Xiaodong Chen
Chief Executive Officer
Blue Hat Interactive Entertainment Technology
7th Floor, Building C, No. 1010 Anling Road
Huli District, Xiamen, China 361009
Re:Blue Hat Interactive Entertainment Technology
Form F-1 filed April 21, 2021
File No. 333-255391
Dear Mr. Chen:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Mindy Hooker at (202) 551-3732 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

October
2, 2020

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, NE

Washington,
D.C. 20549-0405

Attention:
Edward M. Kelly

 RE: Blue
Hat Interactive Entertainment Technology

Registration
Statement on Form F-3

Filed
September 25, 2020

File
No. 333-249056

Ladies
and Gentlemen:

	Blue
Hat Interactive Entertainment Technology (the “Company”) hereby requests that the above-captioned registration statement
(the “Registration Statement”) be declared effective at 4:00 P.M., Eastern Time on Tuesday, October 6, 2020, or as
soon thereafter as may be practicable.

	We
acknowledge that a declaration by the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant
to delegated authority, that the Registration Statement is effective does not foreclose the Commission from taking any action
with respect to the Registration Statement. We further acknowledge that such a declaration of effectiveness does not relieve the
Company from our full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement. We understand
that we may not assert staff comments to the Registration Statement or the declaration of effectiveness by the Commission 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 questions, please do not hesitate to contact the undersigned at sean@bluehatgroup.net or Elizabeth F. Chen of Pryor
Cashman LLP, outside counsel to the Company, at echen@pryorcashman.com (Tel: 212-326-0199).

    Very
    truly yours,

    /s/
    Xiaodong Chen

    Xiaodong
    Chen

    Chief
    Executive Officer

cc:    Elizabeth
Fei Chen, Esq.

United States securities and exchange commission logo
October 1, 2020
Xiaodong Chen
Chief Executive Officer and Director
Blue Hat Interactive Entertainment Technology
7th Floor, Building C, No. 1010 Anling Road
Huli District, Xiamen, People's Republic of China 361009
Re:Blue Hat Interactive Entertainment Technology
Registration Statement on Form F-3
Filed September 25, 2020
File No. 333-249056
Dear Mr. Chen:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action, or absence of action by the staff.
            Please contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Elizabeth Fei Chen, Esq.

CORRESP
1
filename1.htm

Blue
Hat Interactive Entertainment Technology

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

Xiamen,
China 361009

August
27, 2020

VIA
EDGAR

U.S. Securities
and Exchange Commission

Division
of Corporation Finance

100 F
Street, N.E.

Washington,
D.C. 20549

Attn:
    Thomas Jones, Esq.

    Re:
    Blue Hat Interactive Entertainment Technology

    Request for Acceleration of Registration Statement on Form
    F-1, as amended

    File No. 333-246382

Ladies
and Gentlemen:

In
connection with the above-referenced Registration Statement, and pursuant to Rule 461 of the General Rules and Regulations of
the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), Blue Hat
Interactive Entertainment Technology hereby requests acceleration of effectiveness of the above-referenced Registration Statement
so that it will be declared effective at 5:00 p.m., Eastern Time, on August 31, 2020, or as soon as practicable thereafter.

Very
truly yours,

BLUE
HAT INTERACTIVE ENTERTAINMENT TECHNOLOGY

By: /s/
Xiaodong Chen

Name:
Xiaodong Chen

Title:
Chief Executive Officer and Director

United States securities and exchange commission logo
August 20, 2020
Xiaodong Chen
Chief Executive Officer
Blue Hat Interactive Entertainment Technology
7th Floor, Building C, No.1010 Anling Road
Huli District, Xiamen, China 361009
Re:Blue Hat Interactive Entertainment Technology
Registration Statement on Form F-1
Filed August 17, 2020
File No. 333-246382
Dear Mr. Chen:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Thomas Jones at 202-551-3602 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Jolie Kahn, Esq.

CORRESP
1
filename1.htm

Blue Hat Interactive Entertainment Technology

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

Xiamen,
China 361009

July 23, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn:	    John Stickel

J. Nolan McWilliams

    Re:
    Blue Hat Interactive Entertainment Technology

    Request for Acceleration of Registration Statement on Form F-1, as amended

    File No. 333-230051

Ladies and Gentlemen:

In connection with the
above-referenced Registration Statement, and pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange
Commission under the Securities Act of 1933, as amended (the “Securities Act”), Blue Hat Interactive Entertainment
Technology hereby requests acceleration of effectiveness of the above-referenced Registration Statement so that it will be declared
effective at 4:30 p.m., Eastern Time, on July 25, 2019, or as soon as practicable thereafter.

Very truly yours,

BLUE HAT INTERACTIVE ENTERTAINMENT TECHNOLOGY

By: 	/s/ Xiaodong Chen

Name:	Xiaodong Chen

Title:	Chief Executive Officer and Director

      1

ViewTrade Securities, Inc.

7280 W. Palmetto Park Road, Suite 310

Boca Raton, Florida 33433

July 23, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attn:	    John Stickel

J. Nolan McWilliams

    Re:
    Blue Hat Interactive Entertainment Technology

    Request for Acceleration of Registration Statement on Form F-1, as amended

    File No. 333-230051

Ladies and Gentlemen:

Pursuant to Rule 461 of the General
Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, ViewTrade Securities,
Inc., as representative of the underwriters, hereby joins Blue Hat Interactive Entertainment Technology in requesting acceleration
of the effective date of the above-referenced Registration Statement so that it will become effective at 4:30 pm, Eastern Time,
on July 25, 2019, or as soon thereafter as practicable.

The following is supplemental information
supplied under Rule 418(a)(7) and Rule 460 under the Securities Act of 1933:

    (i)
    Date of preliminary prospectus: May 3, 2019.

    (ii)
    Dates of distribution: May 3, 2019 through the date hereof.

    (iii)
    Number of prospective underwriters and selected dealers to whom the preliminary prospectus was furnished: 7.

    (iv)
    Number of prospectuses so distributed: 894.

The undersigned confirms that it
has complied with and will continue to comply with, and it has been informed or will be informed by participating dealers that
they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in
connection with the above-referenced issue.

    Very truly yours,

    ViewTrade Securities, Inc.

    By:
    /s/ Douglas Aguililla

    Name:
    Douglas Aguililla

    Title:
    Director

      2

March 22, 2019
Xiaodong Chen
Chief Executive Officer
Blue Hat Interactive Entertainment Technology
7th Floor, Building C, No. 1010 Anling Road
Huli District, Xiamen, China
Re:Blue Hat Interactive Entertainment Technology
Amendment No. 1 to
Registration Statement on Form F-1
Filed March 18, 2019
File No. 333-230051
Dear Mr. Chen:
            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.
Amendment No. 1 to Form F-1
Description of Share Capital and Governing Documents, page 94
1.We note that Section 164 of your Amended and Restated Memorandum of Association
includes a fee-shifting provision.  Please include disclosure about the fee-shifting
provision, including the following matters: (1) the types of actions subject to fee-shifting,
including whether the company intends to apply the provision to claims under the federal
securities laws; (2) the level of recovery required by the plaintiff to avoid payment; and
(3) who is subject to the provision (e.g., former and current shareholders, legal counsel,
expert witnesses) and who would be allowed to recover (e.g., company, directors, officers,
affiliates).

 FirstName LastNameXiaodong Chen
 Comapany NameBlue Hat Interactive Entertainment Technology
 March 22, 2019 Page 2
 FirstName LastName
Xiaodong Chen
Blue Hat Interactive Entertainment Technology
March 22, 2019
Page 2
In addition, add risk factor disclosure regarding how the provision could discourage
shareholder lawsuits that might otherwise benefit the company and its shareholders.  To
the extent the provision applies to claims under the federal securities laws, clarify in the
risk factor whether you intend to apply the fee-shifting provision to potential claims in the
current offering.
            You may contact Heather Clark at 202-551-3624 or Melissa Raminpour at 202-551-
3379 if you have questions regarding comments on the financial statements and related
matters.  Please contact John Stickel at 202-551-3324 or J. Nolan Mcwilliams at 202-551-3217
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure

December 14, 2018
Xiaodong Chen
Director
Blue Hat Interactive Entertainment Technology
7th Floor, Building C, No. 1010 Anling Road
Huli District, Xiamen, China
Re:Blue Hat Interactive Entertainment Technology
Draft Registration Statement on Form F-1
Submitted November 19, 2018
CIK No: 0001759136
Dear Mr. Chen:
            We have reviewed your draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Form F-1 DRS
General
1.Please provide us with copies of all written communications, as defined in Rule 405 under
the Securities Act, that you, or anyone authorized to do so on your behalf, present to
potential investors in reliance on Section 5(d) of the Securities Act, whether or not they
retain copies of the communications.
2.Please provide us with copies of any additional graphics, maps, photographs, and related
captions or other artwork including logos that you intend to use in the prospectus.  Please
keep in mind, in scheduling printing and distributing of the preliminary prospectus, that
we may have comments after reviewing the materials.

 FirstName LastNameXiaodong Chen
 Comapany NameBlue Hat Interactive Entertainment Technology
 December 14, 2018 Page 2
 FirstName LastName
Xiaodong Chen
Blue Hat Interactive Entertainment Technology
December 14, 2018
Page 2
There can be no assurance that we will not be a passive foreign investment company, page 36
3.Please reconcile your disclosure here that you "do not presently expect to be a PFIC for
the current taxable year or the foreseeable future" with your disclosure on page 104 that
"we expect to be a PFIC for our current taxable year" and "believe that we likely will be a
PFIC under the PFIC income test in future taxable years as well."
Contractual Arrangements, page 46
4.Please revise your discussion of the Exclusive Business Cooperation Agreement to further
describe the adjustment of the service fee paid to Blue Hat WFOE.  Explain under what
conditions it may be adjusted and by which party.
Our Strategy, page 75
5.We note your disclosure here that you intend to open or franchise 50 to 100 additional
stores in 2019 to increase your physical presence in China and over the next 3 years
you plan to open or franchise approximately 500 science and experience stores across
China.  Please discuss the material steps and costs involved with such endeavors, and
disclose the challenges and risks involved with this expansion strategy.  In describing
these trends in your liquidity and capital resources discussion, disclose the
estimated amounts of capital that will be required, to the extent known.
            You may contact Heather Clark at 202-551-3624 or Melissa Raminpour at 202-551-3379
if you have questions regarding comments on the financial statements and related
matters.  Please contact John Stickel at 202-551-3324 or John Dana Brown at 202-551-3859 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure