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.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Amended August 28, 2018
           File No. 001-35561

Dear Mr. Wu:

       We have reviewed your August 28, 2018 amendment and response to our
comment letter
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. Unless we note otherwise, our references to prior comments are to
comments in our
May 18, 2018 letter.

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

Overview, page 4

1.    We note your responses to comments 1 and 2. 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 address the specific artificial intelligence and blockchain
technologies referenced and
 Bruno Wu
FirstName LastNameBruno Wu
Seven Stars Cloud Group, Inc.
Comapany 14, 2018
September NameSeven Stars Cloud Group, Inc.
September 14, 2018 Page 2
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FirstName LastName
         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.
Regulation, page 12

2.       We note your response to comment 3 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.
Overview, page 29

3.       We note your response to comment 7. We note 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.
4.       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.
5.       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.
6.       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.
Revenues, page 35

7.       We note your response to comment 8. 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.
 Bruno Wu
FirstName LastNameBruno Wu
Seven Stars Cloud Group, Inc.
Comapany 14, 2018
September NameSeven Stars Cloud Group, Inc.
September 14, 2018 Page 3
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FirstName LastName
8.       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
         material terms under Corporate Structure on page 7.
9.       We note your response to comments 9 and 13. 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.
Loss from Operations , page 37

10.      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 Form 10-Q
         for the quarter ended June 30, 2018 that you incurred research and
development costs
         during 2018 but none in 2017.
2. Summary of Significant Accounting Policies
(l) Revenue Recognition, page F-12

11.      We note your response to comment 12. Please expand your disclosure to
describe the
         crude oil sales arrangements associated with your joint venture in
Singapore and your
         basis for revenue recognition.
General

12.      We note your disclosure that "[t]his Amendment does not include the
entire Form 10-K."
         In future amendments, please file your full and complete Form 10-K.
Form 10-Q for the Quarter Ended June 30, 2018

Notes to Unaudited Consolidated Financial Statements
11. Related Party Transactions
(d) Crude Oil Trading, page 22

13.      We note during the first six months of 2018, you recorded 10 crude oil
transactions that
         were purchased from three entities on 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