November 26, 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. 2 to Registration Statement on Form F-1
           Filed November 15, 2018
           File No. 333-227198

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 Form F-1 filed November 15, 2018

Exhibits

1.     Please file a legal opinion addressing all of the securities being
registered. For instance,
       please file an opinion regarding the warrants. Please also ensure the
opinion covering the
       ordinary shares addresses all ordinary shares referenced in the fee
table. In this regard we
       note the limitation as to number of ordinary shares in the first
sentence of the opinion filed
       as Exhibit 5.1.
2.     Please file an opinion of counsel that does not contain the limitation
on reliance contained
       in the first sentence of Paragraph 4.4 of Exhibit 5.1. For guidance,
please refer to Section
       II.B.3.d of Staff Legal Bulletin No. 19.
 Ian Huen
Aptorum Group Ltd
November 26, 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
November 26, 2018 Page 2
cc:       Louis Taubman, Esq.
FirstName LastName