United States securities and exchange commission logo September 28, 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. 2 to Registration Statement on Form F-1 Filed September 25, 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. Amendment No. 2 to Registration Statement on Form F-1 Exhibits 1. Please have both counsels revise their opinions to sign the opinions. Please also have Campbells revise its opinion to refer to the number of shares being registered. Ian Huen Aptorum Group Ltd September 28, 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 28, 2020 Page 2 cc: Louis Taubman FirstName LastName