October 9, 2018

Alison Davidson
Interim Chief Financial Officer
Remark Holdings, Inc..
3960 Howard Hughes Parkway, Suite 900
Las Vegas, NV 89169

       Re: Remark Holdings, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed April 2, 2018
           Form 10-Q for the Quarter Ended June 30, 2018
           Filed August 14, 2018
           File No. 001-33720

Dear Ms. Davidson:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 10-K for the Fiscal Year Ended December 31, 2017

Item 7. Management's Discussion and Analysis
Liquidity and Capital Resources
Overview, page 31

1.    We note that your November 9, 2016 agreement with Aspire Capital Fund
capped the
      number of shares you could issue to Aspire at a total of 4,273,471 of
your common
      shares. Please expand your discussions of liquidity and capital resources
to clearly
      describe and quantify known limitations and uncertainties regarding the
liquidity and
      capital resources available to you under your agreements with Aspire
Capital Fund as
      required by Items 303(a)(1) and (2) of Regulation S-K.
 Alison Davidson
Remark Holdings, Inc..
October 9, 2018
Page 2
Form 10-Q for the Quarter Ended June 30, 2018

Note 2. Summary of Significant Accounting Policies
Changes to Significant Accounting Policies - Revenue Recognition
Data Platform Services, page 7

2.       It is unclear to us how your recognition of a "reserve equal to the
total potential loan
         balance that (you) could be required to repay upon default," as
described on page F-9 of
         your Form 10-K, relates to your liability to reimburse affiliates of
banks and lending
         institutions "for a certain percentage of any loan defaults" as stated
in the 10-K and
         hereunder. Please clarify the terms of your agreements requiring you
to reimburse
         lenders' affiliates for loan defaults. Include a comprehensive and
detailed disclosure of
         the contractual terms of your arrangements with such lending
institutions and their
         affiliates and clarify how these transactions are accounted for.
Please also tell us why you
         believe such loan default obligations should be accounted for as
guarantees outside the
         scope of ASC 606.
Notes to the Unaudited Condensed Consolidated Financial Statements
Note 17. Subsequent Events, page 20

3.       Please disclose the material terms of the 2018 Aspire Purchase
Agreement, including
         Aspire Capital's stipulated purchase price for your stock and any cap
on the maximum
         number of shares.
       In closing, 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.

      You may contact Kathryn Jacobson, Senior Staff Accountant at (202)
551-3365 or Joseph
Kempf, Senior Staff Accountant at (202) 551-3352 with any questions.



FirstName LastNameAlison Davidson                              Sincerely,
Comapany NameRemark Holdings, Inc..
                                                               Division of
Corporation Finance
October 9, 2018 Page 2                                         Office of
Telecommunications
FirstName LastName