November 14, 2019

Carlos Moreira
Chief Executive Officer
WISeKey International Holding AG
General-Guisan-Strasse 6
CH-6300 Zug, Switzerland

       Re: WISeKey International Holding AG
           Amendment No. to 1 to Registration Statement on Form 20-F
           Filed November 8, 2019
           File No. 001-39115

Dear Mr. Moreira:

       We have reviewed your filing 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.
References to our prior comments refer to our letter dated October 30, 2019.

Amendment 1 to Form 20-F Filed on November 8, 2019

Item 4. Information on the Company
History and Development of the Company, page 28

1.    You state in your response to prior comment 1 that if the WiseCoin AG
spin-out is
      completed prior to effectiveness, you will provide pro forma information
pursuant to
      Article 11. Please also confirm that to the extent a spin-out is
probable, even it it has not
      yet been completed, you will also provide the required pro forma
information.
Item 10: Addtional Information
Share Capital, page 88

2.    Your disclosure indicates that there is a "voting privilege" for Class A
shares over Class B
      shares due to differences in par value. Beyond the circumstances where
votes are required
      based on par value, it is unclear how Class A shares have a voting
preference in
 Carlos Moreira
WISeKey International Holding AG
November 14, 2019
Page 2
      circumstances where both Class A and Class B shares have one vote per
share. Please
      clarify and consider providing explanatory examples of situations where
investors would
      be allowed to vote for matters that are not one vote per share.
        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 Brittany Ebbertt, Staff Accountant, at (202) 551-3572
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Edwin Kim,
Attorney-Advisor, at
(202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.



                                                           Sincerely,
FirstName LastNameCarlos Moreira
                                                           Division of
Corporation Finance
Comapany NameWISeKey International Holding AG
                                                           Office of Technology
November 14, 2019 Page 2
cc:       Herman H. Rasp . Esq.
FirstName LastName