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                           May 10, 2022

       Frank Sun
       Chief Financial Officer
       Q&K International Group Ltd
       Suite 1607, Building A, No.596 Middle Longhua Road
       Xuhui District, Shanghai, 200032
       People   s Republic of China

                                                        Re: Q&K International
Group Ltd
                                                            Form 20-F for the
fiscal year ended September 30, 2021
                                                            Filed February 15,
2022
                                                            File No. 001-39111

       Dear Mr. Sun:

              We have reviewed your February 15, 2022 response to our comment
letter and have the
       following comment. 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 comment 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
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this comment, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       January 24, 2022 letter.

       Form 20-F filed February 15, 2022

       Item 3. Key Information, page 9

   1.                                                   We note your response
to comment 6. Please identify the entities that comprise the
                                                        column,
Consolidate[d] Subsidiaries.    The WFOE that is the primary beneficiary to the
                                                        VIE should be presented
in a separate column, so an investor may gain an understanding
                                                        of how the WFOE
transacts with the VIE and with its parent. Please tell us how this
                                                        agreement and other
pertinent agreements are reflected in the condensed consolidating
                                                        schedule.
 Frank Sun
Q&K International Group Ltd
May 10, 2022
Page 2

      You may contact Jeffrey Lewis, Staff Accountant, at (202) 551-6216 or
Shannon
Menjivar, Accounting Branch Chief, at (202) 551-3856 with any questions.



FirstName LastNameFrank Sun                             Sincerely,
Comapany NameQ&K International Group Ltd
                                                        Division of Corporation
Finance
May 10, 2022 Page 2                                     Office of Real Estate &
Construction
FirstName LastName