August 1, 2019

Sanjun Kuang
Chief Executive Officer
GJ Culture Group US, Inc.
4125 Blackhawk Plaza Circle, Suite 166
Danville, CA 94506

       Re: GJ Culture Group US, Inc.
           Registration Statement on Form S-1
           Filed on July 11, 2019
           File no. 333-232605

Dear Mr. Kuang:

       We have reviewed your registration statement 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-1 filed July 11, 2019

Our success depends on the continuing efforts of our senior management team and
other key
personnel. , page 5

1.     Please revise the body of your risk factor to name the senior management
team and key
       personnel upon whom you rely.
Description of Business, page 15

2.     Please revise to discuss all regulations material to conducting the
company's operations.
       Please refer to Item 101((h)(4)(ix) of Regulation S-K.
 Sanjun Kuang
FirstName LastNameSanjun Kuang
GJ Culture Group US, Inc.
Comapany2019
August 1, NameGJ Culture Group US, Inc.
August 1, 2019 Page 2
Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and results of
Operations
General, page 39

3.       We note that "revenues are comprised of providing promotions to your
partner, who gives
         international study tour services and commission to be received from
partner enrollment
         services". We also note that you describe your business on page 1 as
providing
         educational services. Please expand your description of revenues to
clarify whether you
         provide the educational services or whether you only receive
commissions for enrolling
         customers in your partner's educational services. Please also expand
your revenue
         recognition accounting policy on pages 46, F-10 and F-24 and
description of business
         elsewhere in the document accordingly.
Results of Operations, page 40

4.       We note that you expect to record the commission received from the
partner for the
         enrollment service in the second or third fiscal quarter of 2019.
Please expand the
         discussion to explain the nature and timing of recognizing the
commission and whether
         the enrollment service has been provided prior to March 31, 2019 and
are included in
         accounts receivable as of March 31, 2019 or whether these services are
discussed as
         subsequent events. Also, please quantify the amounts already provided,
if applicable.
Cash Flows, page 41

5.       Please expand your discussion of investing activities on page 42 to
describe the types of
         intangible assets acquired.
Liquidity and Capital Resources, page 43

6.       We note that you state that you plan to fund your operations through
the proceeds of
         offering pursuant to a Registration Statement on Form S-1. Please
expand the disclosure
         to clarify that you will receive no proceeds from the sale of shares
underlying this Form S-
         1, as only selling shareholders will receive the proceeds. Please also
revise the disclosure
         on pages F-8 and F-23 accordingly.
Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2

7.       Please have your public accounting firm revise the wording of their
review report so that
         the referenced audited period is the period covered by their audit
report dated April 25,
         2019. That is, the period covered is from the date of inception to
December 31, 2018
         rather than the year ended December 31, 2018.
Note 3. Summary of Significant Accounting Policies, page F-23

8.       Please expand your revenue recognition accounting policy to address
your relationship
         with your partner, whether you receive commissions for enrolling
customers in
 Sanjun Kuang
FirstName LastNameSanjun Kuang
GJ Culture Group US, Inc.
Comapany2019
August 1, NameGJ Culture Group US, Inc.
Page 3
August 1, 2019 Page 3
FirstName LastName
         educational services provided by your partner or whether you pay your
partner
         commissions and you are responsible for providing the educational
services. Please
         disclose the basis for recording revenue as a principal versus agent.
Refer to ASC 606-10-
         55-36 for guidance.
Exhibits

9.       Please revise the opinion of counsel to indicate that the shares are
legally issued, fully
         paid, and non-assessable under Nevada law. Please refer to Staff Legal
Bulletin 19,
         Section II.B.1., Substance of Legality Opinions.
Consent of WWC, P.C., page II-1

10.      Refer to the Consent of WWC, P.C. in exhibit 23.1. We note that the
report from WWC
         on page F-17 covers the period from the date of inception December 20,
2018 to
         December 31, 2018. We also note that the consent refers to the "year
then ended". Please
         have your public accounting firm revise their consent to be consistent
with their audit
         report.
General

11.      We note that you cite to industry research for information and
statistics regarding
         economic trends. Please provide us with marked copies of any materials
that support
         these and other third party statements, clearly cross-referencing a
statement with the
         underlying factual support. Confirm for us that these documents are
publicly available.
         Tell us whether any of the reports, other than those prepared by the
government, were
         prepared for you or in connection with the offering. We note, by way
of example only, the
         reference to the Zero Power Intelligence Research Institute at page
15.




        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Sanjun Kuang
GJ Culture Group US, Inc.
August 1, 2019
Page 4

        You may contact Claire DeLabar, Staff Accountant, at 202-551-3349, or
Robert S.
Littlepage, Accounting Branch Chief, at 202-551-3361, if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Staff
Attorney, at 202-551-3415, or Larry Spirgel, Assistant Director, at
202-551-3815, with any other
questions.



                                                           Sincerely,
FirstName LastNameSanjun Kuang
                                                           Division of
Corporation Finance
Comapany NameGJ Culture Group US, Inc.
                                                           Office of
Telecommunications
August 1, 2019 Page 4
cc:       Yue Cao
FirstName LastName