January 13, 2020 Ian Huen Chief Executive Officer and Executive Director Aptorum Group Ltd 17th Floor, Guangdong Investment Tower 148 Connaught Road Central Hong Kong Re: Aptorum Group Ltd Registration Statement on Form F-3 Filed January 6, 2020 File No. 333-235819 Dear Mr. Huen: 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 Irene Paik at 202-551-6553 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Louis Taubman