September 14, 2018

Bruno Wu
Chief Executive Officer
Seven Stars Cloud Group, Inc.
No. 4 Drive-in Movie Theater Park
No. 21 Liangmaqiao Road, Chaoyang District
Beijing 10015
People's Republic of China

       Re: Seven Stars Cloud Group, Inc.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed August 24, 2018
           File No. 333-224382

Dear Mr. Wu:

      We have reviewed your amended 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. Unless
we note
otherwise, our references to prior comments are to comments in our May 17, 2018
letter.

Registration Statement on Form S-1/A filed August 24, 2018

Prospectus Summary, page 1

1.     We note your responses to comments 2 and 5. We again ask you to provide
more detail,
       description, and elaboration regarding your "next generation
Artificial-Intelligent (AI)
       & Blockchain-Powered, Fintech" businesses. It is still unclear how the
company precisely
       intends to accomplish the digital asset securitization, tokenization,
and trading goals it
       briefly describes. Enhance your disclosures by addressing each of these
items. Please also
 Bruno Wu
FirstName LastNameBruno Wu
Seven Stars Cloud Group, Inc.
Comapany 14, 2018
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September 14, 2018 Page 2
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FirstName LastName
         address the specific artificial intelligence and blockchain
technologies referenced and how
         they interact with your digital asset securitization, tokenization,
and trading goals. We also
         note your disclosures regarding digital assets, related platforms, and
sales and
         monetization networks. Provide more specific detail regarding each of
these elements of
         your strategy. Discuss how all of these concepts, operations, etc.
interact with your
         "supply chain ecosystem" if at all. Clarify how the "Venus blockchain
based platform" is
         integrated into your business and what exactly this platform entails.
2.       We note your response to comment 9. Please revise your statement that
"DBOT is an
         SEC recognized Alternative Trading System" to state that DBOT has
filed an initial
         operations report on Form ATS to give notice of its operation as an
ATS.
3.       We note your statements that you believe DBOT can be developed into a
distributed
         network but we also note your statement that DBOT is currently run on
a "customized
         private Ethereum blockchain distribution ledger system." Please
clarify as it is unclear
         how or if blockchain technology has been integrated into DBOT at this
time.
4.       We note your response to comment 10. Please provide more detail as to
how your
         proposed digital asset products, platforms, exchanges, and networks
interact, or will
         interact, with DBOT. Describe the current status of integration
between DBOT and these
         entities.
Overview, page 20

5.       We note your response to comment 11. We note on page 20 you disclose
that your two
         current revenue sources are your supply chain management & structured
finance and
         alternative finance & carry trade businesses, and that you are
primarily engaged with
         consumer electronics and smart supply chain management operations.
Please focus your
         discussion on the particulars of your revenue arrangements that were
in effect during
         2017, such as the sale of crude oil and electronics.
Revenues , page 31

6.       We note your response to comments 12 and 19. It appears from your
disclosure in Note
         12(g) that you recorded a sale transaction based on your collection of
a prepayment from
         an intermediary. Please clarify the intermediary role of the entity on
which your minority
         shareholder has significant influence, and the nature of its
involvement with you and the
         end customer in the subject transaction. Further provide us your
analysis as to why it is
         appropriate to record the gross volume of the sale transaction upon
delivery versus the
         amount that you are allowed to retain. Refer to the indicators under
ASC 605-45-45.
7.       Please identify your business partner, a newly controlled Singapore
joint venture. Please
         disclose the nature of the joint venture and its business operations,
your respective interest
         (or variable interest), your basis of accounting for the joint
venture, and the assets
         contributed at formation. Include a footnote referencing the
underlying agreement and
 Bruno Wu
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Seven Stars Cloud Group, Inc.
Comapany 14, 2018
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         material terms under Corporate Structure on page 42.
8.       We note your response to comment 13. It is unclear to us why you
attribute your revenue
         growth drivers for the sales of electronics and crude oil products to
your technology
         platforms and blockchain-based digital asset management platform which
are not fully
         functional. Please revise to identify more relevant factors that
contributed to your sales
         growth, including your geographic reach, customer sectors, product
demand, and other
         external factors. Further explain what was involved in the setup of
"two industrial
         vehicles for commercial electronics in Hong Kong and oil trading in
Singapore" and your
         basis for the measurement and recognition of revenues therefrom.
Loss from Operations, page 33

9.       Please tell us how you accounted for development costs of your
technology platform and
         how they impacted your loss from operations. In this regard, we note
in your Unaudited
         Consolidated Statements of Operations for the quarter ended June 30,
2018 on page F-43
         that you incurred research and development costs during 2018 but none
in 2017.
Corporate Structure, page 42

10.      We note your response to comment 4. Revise your corporate structure
chart to clearly
         indicate where each of your subsidiaries, WFOEs, and VIEs are
geographically located.
Regulation, page 48

11.      We note your response to comment 16 but do not concur with your
assertion that your
         current disclosures in this section are responsive to our comment.
Please update this
         section to discuss laws and regulations that will be applicable to
your fintech businesses.
2. Summary of Significant Accounting Policies
(1) Revenue Recognition, page F-12

12.      We note your response to comment 19. Please expand your disclosure to
describe the
         crude oil sales arrangements associated with your joint venture in
Singapore and your
         basis for revenue recognition.
Notes to Unaudited Consolidated Financial Statements
11. Related Party Transactions
(d) Crude Oil Trading, page F-60

13.      We note during the first six months of 2018, you recorded 10 crude oil
transactions that
         were purchased from three entities for which a minority shareholder
has significant
         influence. Please disclose:
           the nature of your relationships and involvement with the entities
for which a minority
         shareholder has significant influence;
           the amount of sales to related parties; and
 Bruno Wu
Seven Stars Cloud Group, Inc.
September 14, 2018
Page 4
        clarify whether "crude oil trading" is intended to mean sales of crude
oil.
       You may contact Kathryn Jacobson, Senior Staff Accountant, at (202)
551-3365 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 William
Mastrianna, Attorney-Adviser, at (202) 551-3778 or Celeste M. Murphy, Legal
Branch Chief, at
(202) 551-3257 with any other questions.



                                                             Sincerely,
FirstName LastNameBruno Wu
                                                             Division of
Corporation Finance
Comapany NameSeven Stars Cloud Group, Inc.
                                                             Office of
Telecommunications
September 14, 2018 Page 4
cc:       William Haddad
FirstName LastName