United States securities and exchange commission logo





                              September 25, 2020

       Ian Huen
       Chief Executive Officer and Executive Director
       Aptorum Group Ltd
       17 Hanover Square
       London W1S 1BN, United Kingdom

                                                        Re: Aptorum Group Ltd
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed September 24,
2020
                                                            File No. 333-248743

       Dear Mr. Huen:

             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
September 21, 2020 letter.

       Amendment No. 1 to Registration Statement on Form F-1, Filed September
24, 2020

       Cover Page

   1.                                                   We note your response
to our prior comment number 1. As required by Item 501(b)(8)(iii)
                                                        of Regulation S-K,
please revise the cover page of the prospectus to expressly provide the
                                                        date that the offering
will end.
   2.                                                   We note your revised
disclosure in response to prior comment 1 that you do not have an
                                                        arrangement to place
the proceeds from this offering in an escrow, trust or similar
                                                        account, and that the
funds will be immediately available to you and not refunded. Please
                                                        further expand on your
disclosure by explaining the significant risks to investors that arise
                                                        from not having such
arrangements in place.
 Ian Huen
Aptorum Group Ltd
September 25, 2020
Page 2

       Please contact Margaret Schwartz at 202-551-7153 or Dorrie Yale at
202-551-8776 with
any questions.



                                                         Sincerely,
FirstName LastNameIan Huen
                                                         Division of
Corporation Finance
Comapany NameAptorum Group Ltd
                                                         Office of Life
Sciences
September 25, 2020 Page 2
cc:       Louis Taubman
FirstName LastName