Mail Stop 3561
                                                             March 6, 2018


Mr. Brent Y. Suen
Chief Executive Officer
Weyland Tech, Inc.
198 Wellington Street
8/F The Wellington
Central, Hong Kong SAR
Hong Kong HKSAR

        Re:      Weyland Tech, Inc.
                 Form 10-K for Fiscal Year Ended December 31, 2016
                 Filed March 31, 2017
                 File No. 000-51815

Dear Mr. Suen:

        We have reviewed your February 7, 2018 response to our comment letter
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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.
Unless we note otherwise, our references to prior comments are to comments in
our December 1,
2017 letter.

Form 10-K for Fiscal Year Ended December 31, 2016

Financial Statements for the Year Ended December 31, 2016

Note 2   Summary of Significant Accounting Policies

Revenue Recognition, page F-8

    1. We note you indicate in your response to comment 3 that the contracts
you describe on
       pages 11 and 13 all represent the same types of contracts for which you
used different
       terminology. However, we also note from your response that under your
reseller model
       your resellers and distributors provide "Level One Service" consisting
of the resellers' or
 Mr. Brent Suen
Weyland Tech, Inc.
March 6, 2018
Page 2

       distributors' end customer facing sales and support including help
desks, technical
       support, mobile and website design, marketing and promotions to such end
users and that
       they receive compensation for those services. It also appears that you
may provide these
       services for your direct sales. To help us better understand how you
generate revenue,
       please respond to the following:

           Please tell us whether you compensate the resellers and distributors
for providing
           these services, or whether the end user customer pays the
reseller/distributor directly
           for these services. If you compensate your reseller/distributor
customers for
           providing these services, please tell us how you considered this
when recognizing the
           revenues and costs associated with these contracts and explain how
you considered
           the guidance in ASC 605-10-25 and 605-25-25 in recognizing revenues
for these
           contracts. Specifically please address whether these contracts
represent multiple
           element arrangements, and if so, how you determined whether any of
these
           deliverables represent a separate unit of account and why, or why
not. If you
           determined that any of these deliverables represent a separate unit
of account please
           tell us and disclose how you allocated revenues to the various
deliverables. Please
           provide your basis in GAAP for your accounting.

           For your direct sales of the CreateApp platform, please tell us and
disclose whether
           you provide the same types of services to your customers that your
           resellers/distributors provide to their end user customers. If so,
please tell us how you
           recognize revenues for these services and how you considered the
guidance in ASC
           605-10-25 and 605-25-25. Please specifically address whether these
contracts
           represent multiple element arrangements, and if so, how you
determined whether any
           of these deliverables represent a separate unit of account and why,
or why not. If you
           determined that any of these deliverables represent a separate unit
of account please
           tell us and disclose how you allocated revenues to the various
deliverables. Please
           provide your basis in GAAP for your accounting.

           We note from your response that approximately 18% of your revenues
were
           comprised of income from providing development services. Please tell
us whether
           you or your reseller/distributor customers customize the
"white-label" versions for
           certain of your CreateApp platform resellers/distributors. For
contracts where you
           provide these customization services for your reseller/distributor
customers or your
           direct customers, tell us what compensation you receive for these
services, whether
           these services are bundled with software licenses and other services
and how you
           recognize related revenues. Please refer to ASC 605-35-25. Please
also expand your
           accounting policy footnote to disclose in more detail your
accounting for such
           revenues and related costs.

           It appears from your response that you do not sell software licenses
and instead you
           generate revenue solely through the Software as a Service model.
Please revise future
           filings to more clearly explain this to your readers, as your
previous filings contained
 Mr. Brent Suen
Weyland Tech, Inc.
March 6, 2018
Page 3

           references to license sales that suggested you generated revenue in
part from selling
           software licenses.

Note 3   Intangible Assets, page F-10

    2. In light of the fact that approximately 39 percent of your total assets
are intangible assets
       consisting almost entirely of software developed by you, please provide
an accounting
       policy which addresses your criteria for capitalizing these assets.
Please refer to ASC
       985-20-25.

Item 9 A(T). Controls and Procedures

Evaluation of Disclosure Controls and Procedures, page 16

    3. Your response to comment 5 indicates that you believe your "internal
controls and
       procedures" were effective as of December 31, 2016. We have the
following comments:

           When you amend your Form 10-K, please revise your disclosures to
either refer to
           disclosure controls and procedures or to separately refer to
internal control over
           financial reporting. Please note the phrase "internal controls and
procedures" should
           not be used in your disclosures under Item 9A as it appears to be a
combination of the
           terms "disclosure controls and procedures" and "internal control
over financial
           reporting," and using the phrase "internal controls and procedures"
does not satisfy
           your disclosure requirements under Items 307 and 308 of Regulation
S-K.

           Since your Form 10-K did not contain the conclusions of your
management regarding
           the effectiveness of your disclosure controls and procedures as
required by Item 307
           of Regulation S-K, it appears your disclosure controls and
procedures were not
           effective to ensure that all information required to be disclosed in
your Form 10-K
           was disclosed within the time periods specified in our rules and
forms. It further
           appears from your response to comment 5 that the disclosure you made
regarding
           your identification of material weaknesses was incorrect as it
erroneously repeated
           the prior year's disclosure despite the fact that those deficiencies
were corrected
           during 2016. This appears to provide further evidence that your
disclosure controls
           and procedures were not effective to ensure that all information
required to be
           disclosed in your Form 10-K was disclosed within the time periods
specified in our
           rules and forms. As such, it appears your amended Form 10-K should
state that your
           disclosure controls and procedures were not effective as of December
31, 2016.
 Mr. Brent Suen
Weyland Tech, Inc.
March 6, 2018
Page 4

       You may contact Sondra Snyder, Staff Accountant at (202) 551-3332 or me,
at (202)
551-3737 if you have questions regarding comments on the financial statements
and related
matters. Please contact Courtney Haseley, Staff Attorney at (202) 551-7689 or
Lisa Kohl, Legal
Branch Chief at (202) 551-3252 with any other questions.


                                                          Sincerely,

                                                          /s/ Jennifer Thompson

                                                          Jennifer Thompson
                                                          Accounting Branch
Chief
                                                          Office of Consumer
Products