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                              September 15, 2022

       Xin Guan
       Chief Executive Officer
       Ucommune International Ltd
       Guang Hua Road, No 2 , Tower D, Floor 8
       Chaoyang District , Beijing 10002

                                                        Re: Ucommune
International Ltd
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2021
                                                            Filed May 10, 2022
                                                            File No. 001-39738

       Dear Ms. Guan:

              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.

       Form 20-F for the Fiscal Year Ended December 31, 2021

       Item 5. Operating and Financial Review and Prospects
       A. Operating Results
       Year Ended December 31, 2021 Compared to Year Ended December 31, 2020,
page 103

   1.                                                   Where you attribute
material fluctuations in your results of operations to multiple factors,
                                                        please quantify each
factor cited so that investors may understand the magnitude and
                                                        relative impact of each
factor and also describe the reasons underlying the causes. For
                                                        example, you attribute
the increase in other services revenues and cost of revenue to
                                                        increased net revenues
and increased costs in interior design and construction services and
                                                        increase revenue in
SAAS services. Please quantify these items and explain the
                                                        underlying reasons
behind the increases. Please also consider expanding your disclosure
                                                        of general and
administrative expenses and elsewhere, to the extent appropriate.
 Xin Guan
FirstName
UcommuneLastNameXin      Guan
           International Ltd
Comapany 15,
September NameUcommune
              2022           International Ltd
September
Page 2    15, 2022 Page 2
FirstName LastName
Net Revenue, page 103

2.       Please explain in greater detail how workspace membership services
revenues decreased
         11% due to the closure of unprofitable spaces in operation and the
contraction of your
         self-operated coworking space services as you transform to an
asset-light model. The
         disclosure appears to place importance on "spaces." Based on a review
of your operating
         metrics found on page 65 while the number of spaces under your
self-operated model
         declined, it was only by 1 space and the number of asset-light model
spaces increased by
         40 spaces for a net increase in spaces of 39 in 2021. Please explain
more clearly how
         workspace membership services revenues decreased despite a favorable
increase in
         spaces. Additionally, the majority of the remaining operating metrics
appear to show
         favorable trends, including an increase in members. Please explain
what impact, if any,
         the favorable trends in the remaining metrics and the unfavorable
trend in occupancy rates
         had your workspace membership services revenue. Furthermore, we note
disclosure
         elsewhere that COVID negatively impacted your results of operations in
2022 including
         revenue (page F-21). Please explain the extent to which COVID had an
impact here.
Impairment Loss on Long-lived Assets and long-term prepaid expenses, page 104

3.       Please explain in reasonable detail the underlying reasons, events or
changes in
         circumstances that lead to the impairments.
        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 Scott Stringer at 202-551-3272 or me at 202-551-3651 if
you have
questions regarding our comments.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Trade &
Services