MDJM LTD 

Via EDGAR

Division of Corporation Finance

Office of Real Estate & Construction

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

Attention:	James Lopez
	Ruairi Regan

February 1, 2023

Re:	MDJM LTD
	Registration Statement on Form F-3, as amended (File No. 333-261347)
	Initially Filed November 24, 2021

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, MDJM LTD hereby requests acceleration of effectiveness of the above referenced Registration Statement, so that it will become effective at 4:30 p.m. ET on February 3, 2023, or as soon as thereafter practicable.

Very truly yours,

/s/ Siping Xu

Name: Siping Xu

Title: Chief Executive Officer, Director, and
Chairman of the Board of Directors

cc:	Ying Li, Esq.
	Hunter Taubman Fischer & Li LLC