May 18, 2018

Robert Benya
President
Seven Stars Cloud Group, Inc.
Room 4, Fenghuayuan Drive-in Movie Theater Park
No. 21, Liangmaqiao Road, Chaoyang District
Beijing 10015
People's Republic of China

       Re: Seven Stars Cloud Group, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 30, 2018
           File No. 001-35561

Dear Mr. Benya:

       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 amending
your filing or by
advising 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 and any amendment you may file in response
to these
comments, we may have additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2017

Overview, page 4

1.    We note that you are trying to establish "business ecosystem" based on a
"7-3-2-1"
      approach. Please explain what your "business ecosystem" entails. Please
also revise your
      disclosure to describe in plain-English your structural approach. For
example, explain
      what the blockchain-based technology platforms and distribution networks
are and how
      you plan to acquire and use them.
2.    We note that, beginning in 2017, you are aiming to become a "next
generation Artificial-
      Intelligent (AI) & Blockchain-Powered, Fintech company." Please describe
in plain-
 Robert Benya
FirstName LastNameRobert Benya
Seven Stars Cloud Group, Inc.
Comapany NameSeven Stars Cloud Group, Inc.
May 18, 2018
May 18, 2018 Page 2
Page 2
FirstName LastName
         English what services you plan to provide. Further expand your
disclosure to discuss what
         those services will entail and how you plan to provide them.
Regulation, page 11

3.       Please expand your Regulations section to discuss laws and regulations
that will be
         applicable to your planned Fintech business. Discuss which government
entities enforce
         these laws and regulations.
Risk Factors, page 13

4.       To the extent your management's experience is limited in your new line
of business of
         providing the Fintech services you reference, please consider
providing a risk factor to
         this effect.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview, page 28

5.       Please provide the basis for which you describe DBOT as "a blockchain
based alternative
         Trading System fully licensed by the SEC."
6.       Please provide a plain-English description of a "block chain based
Alternative Trading
         System." In this description, please expand on how block chain is
incorporated or
         otherwise relevant to the trading system.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Our ability to make our products remain competitive, page 29

7.       Please expand your discussion of your consumer electronics e-commerce
and smart
         supply chain management operations to include some background
information on revenue
         arrangements and sales channels for electronics products and crude
oil. Please make clear
         how your customers utilize, or benefit from, your products and
services. We note your
         disclosure in the penultimate paragraph on page 4.
Revenues, page 31

8.       Please describe the growth drivers for your revenues from sales of
electronics and crude
         oil products arising from the operation of your Engine 7 " Supply
Chain Finance and
         Management for Vertical Products" which you referenced in your
Prospectus Summary.
         Refer to Item 303(A)(3)(iii) of Regulation S-K.
9.       Please also disclose the nature of revenue transactions with related
parties amounting to
         $18.9 million as reported on page 26, including such other information
deemed necessary
         to an understanding of the effects of the transactions on the
financial statements.
 Robert Benya
FirstName LastNameRobert Benya
Seven Stars Cloud Group, Inc.
Comapany NameSeven Stars Cloud Group, Inc.
May 18, 2018
Page 3
May 18, 2018 Page 3
FirstName LastName



Licensed Content, page 32

10.      It appears that your Legacy YOD revenues from licensed content have
significantly
         decreased from $4.5 million in 2016 to $794,273 in 2017. Please tell
us and disclose your
         assessment of the recoverability of the licensed content intangible
asset and describe
         your major inputs and assumptions. Additionally disclose your basis
for amortizing this
         asset and advise us.
Directors, Executive Officers and Corporate Governance
Summary of Qualifications of Current Directors, page 44

11.      Please confirm that the disclosures here have been updated as
applicable to account for
         your planned Fintech operations.
Revenue Recognition, page F-12

12.      Please describe your revenue arrangements for consumer electronics
e-commerce and
         smart supply chain management operations and trading platforms in
order that your
         investors may better understand how the underlying sales transactions
evolve and how
         you earn revenues.
Accounts Receivable, page F-22

13.      We note your "revenue from related party" on page F-4. Please disclose
the receivable
         amounts due from such related party and the manner of settlement.
Refer to paragraphs
         50-1(d) and 50-2 of ASC 850-10.
12. Related Party Transactions, page F-26

14.      Please clarify how the disposal of Zhong Hai Shu Xun Media impacted
your Legacy YOD
         business. Further, please explain why the licensed content did not
convey with the
         disposal transaction.
15.      In order that your investors may better understand the significance of
your transactions
         with related parties, please summarize the dollar amounts of the
transactions reported
         hereunder for each of the periods for which income statements are
presented and the
         respective income statement captions. Refer to ASC 850-10-50-1(C).
 Robert Benya
Seven Stars Cloud Group, Inc.
May 18, 2018
Page 4



        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 Kathryn Jacobson, Staff Accountant, at 202-551-3365 or
Robert
Littlepage, Accountant Branch Chief, at 202-551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Courtney Lindsay,
Staff Attorney, at 202-551-7237 or Celeste Murphy, Legal Branch Chief, at
202-551-3257 with
any other questions.

FirstName LastNameRobert Benya
Comapany NameSeven Stars Cloud Group, Inc.
                                                          Division of
Corporation Finance
May 18, 2018 Page 4                                       Office of
Telecommunications
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