October 11, 2018

Ian Huen
Chief Executive Officer
Aptorum Group Ltd
17th Floor, Guangdong Investment Tower
148 Connaught Road Central
Hong Kong

       Re: Aptorum Group Ltd.
           Amendment No.1 to Registration Statement on Form F-1
           Filed October 5, 2018
           File No. 333-227198

Dear Mr. Huen:

       We have reviewed your amended registration statement and have the
following
comment. In our comment, 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 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 the comment, we may have additional comments. Unless we
note
otherwise, our references to prior comments are to comments in our September
20, 2018 letter.

Amendment No. 1 to Form F-1 filed on October 5, 2018

Our Business
Statistical Significance, page 82

1.     We note your response to comment 4 and your disclosure that you do not
intend to use for
       any regulatory submission the standard of statistical testing that you
have employed to
       compare different treatment groups. Please revise your disclosure to
explain how
       standards for statistical significance relate to the U.S. Food and Drug
Adminstration's
       evidentiary standards of efficacy.
 Ian Huen
Aptorum Group Ltd
October 11, 2018
Page 2

       You may contact Keira Nakada at 202-551-3659 or Angela Connell at
202-551-3426 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Christine Westbrook at 202-551-5019 or Mary Beth Breslin at
202-551-3625 with any
other questions.



                                                          Sincerely,
FirstName LastNameIan Huen
                                                          Division of
Corporation Finance
Comapany NameAptorum Group Ltd
                                                          Office of Healthcare
& Insurance
October 11, 2018 Page 2
cc:       Louis Taubman, Esq.
FirstName LastName