July 24, 2019

Richard Wei
Chief Financial Officer
ECMOHO Ltd
3F, 1000 Tianyaoqiao Road
Xuhui District
Shanghai, 200030
The Peoples Republic of China

       Re: ECMOHO Ltd
           Draft Registration Statement on Form F-1
           Filed June 28, 2019
           CIK 0001763197

Dear Mr. Wei:

       We have reviewed your draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-1

Corporate History and Structure, page 4

1.     Because investors will be investing in a holding company that does not
directly own all of
       its operations in China, please make this fact clear in your prospectus
summary. In this
       regard, please clearly describe the business of your variable interest
entity, as
       distinguished from your other subsidiaries. Please also disclose in this
section the fact that
       the shareholders of your VIE may have interests that conflict with you,
as you state on
       page 35.
 Richard Wei
FirstName LastNameRichard Wei
ECMOHO Ltd
Comapany NameECMOHO Ltd
July 24, 2019
July 24, 2019 Page 2
Page 2
FirstName LastName



Implications of Being an Emerging Growth Company, page 6

2.       Please revise your disclosure to clarify, if true, that you will
comply with new or revised
         accounting standards when they are adopted by private companies rather
than when they
         are adopted by public companies. Similar revisions should be made to
paragraph four
         on page 48 and to paragraph two on page 50.
The Offering, page 8

3.       Please add a brief description of the material terms of your ADSs.
Risk Factors
Our Success Depends Upon Our Ability..., page 14

4.       We note your disclosure about the small number of brand partners that
contributed a
         significant portion of your revenue in 2018. Revise to state whether
the reduction in
         brand partners as of May 31, 2019, as disclosed on page 12, has had a
material impact
         upon the amounts you disclose here.
Selected Consolidated Financial and Operating Data
Selected Consolidated Statements of Comprehensive Income Data, page 65

5.       Please revise the inconsistency in the description of the gross income
line item to coincide
         with the gross profit description presented in your summary
consolidated statements of
         comprehensive income data on page 10 and in your consolidated
statements of
         comprehensive income on page F-5 or advise.
6.       Please revise footnote (1) to include accretion to redemption value of
redeemable non-
         controlling interests and the related amounts for the periods
presented. Please also
         disclose the amounts in footnote (1) related to the accretion on Round
A and Round B
         convertible redeemable preferred shares to redemption, the accretion
on Series A
         convertible redeemable preferred shares to redemption value, and the
extinguishment of
         convertible redeemable preferred shares for the periods presented.
Similar revisions
         should be made to the summary consolidated statements of comprehensive
income data on
         page 10.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Components of Results of Operations
Net Revenues, page 69

7.       You state that you expect net revenues to increase as you continue to
expand your brand
         partner portfolio and product and service offerings. Yet, in the table
on page 67, we note
         that your brand partners decreased from 52 to 38 partners or 27% from
December 31,
         2018 through the five months ended May 31, 2019. Additionally, the
number of brands
 Richard Wei
FirstName LastNameRichard Wei
ECMOHO Ltd
Comapany NameECMOHO Ltd
July 24, 2019
July 24, 2019 Page 3
Page 3
FirstName LastName
         decreased from 76 to 59 or 22% for the same period. In that regard,
please tell us why
         you believe net revenues will continue to increase. In light of the
above, please also tell
         us whether you still expect cost of revenues to increase.
Critical Accounting Policies, page 71

8.       Your critical accounting policies in relation to revenue recognition,
sales incentives,
         inventories, and share-based compensation does not address the
material implications of
         uncertainties associated with the methods, assumptions, and estimates
underlying such
         measurements. Please revise your critical accounting policies to
present your analysis of
         the uncertainties involved in applying an accounting principle at a
given time or the
         variability that is reasonably likely to result from its application
over time. Refer to
         Section V of SEC Release No. 33-8350.
Results of Operations
Year Ended December 31, 2018 Compared to Year Ended December 31, 2017, page 78

9.       We note your discussion and analysis that multiple factors impacted
your results of
         operations. For example, you state that product sales revenues
increased due to high
         growth in the sales of products and the introduction of new brands of
health supplements.
         To the extent that multiple factors influenced changes in your results
of operations, please
         revise your disclosure to quantify the impact of each factor you
identify. Refer to
         SEC Release No. 33-8350.
10.      We note your disclosure on page F-21 that your CODM reviews
consolidated results
         including, revenue, gross profit and operating profit. Please expand
your disclosure to
         provide a discussion and analysis of the changes in gross profit.
Similar revisions should
         be made to your discussion of key components of results of operations
on page 69.
Liquidity and Capital Resources, page 80

11.      Please expand your disclosure to discuss your ability to transfer cash
between entities,
         across borders, and to U.S. investors as reference to your Holding
Company Structure
         disclosure on page 77 only address the payment of dividends. Refer to
Item 303(a)(1) of
         Regulation S-K and Section IV of SEC Release No. 33-8350.
Business
Our Strengths, page 89

12.      Where you discuss your repeated purchases for 2018 on page 90, please
enhance your
         discussion to contextualize and quantify your repeated purchases for
prior periods in order
         to explain its importance. In this regard, we note your disclosure on
page 12 that the
         repeat purchase rate increased 2% from 2017 to 2018.
 Richard Wei
ECMOHO Ltd
July 24, 2019
Page 4


Brand Partners Development and Services, page 95

13.      We note your disclosure that "three of the ten largest brand partners
in terms of revenue
         contribution in 2018 are under the common control of a global food and
beverage
         company". Please tell us what consideration you have given to the
filing of these
         agreements. Please refer to Item 601(b)(10) of Regulation S-K.
14.      You present case studies of customers that have utilized your
services. Please confirm
         that the customers have consented to these statements and to their
case studies being used
         in your registration statement.
XG Health platform , page 97

15.      We note your disclosure that "[c]onsumers may purchase these products
for themselves or
         share the links to these products on social media and earn
commissions." Please indicate
         whether or not you are responsible for paying these commissions and
quantify, if material.
Description of American Depositary Shares , page 139

16.    We note your disclosures on page 148 that each party to the deposit
agreement
       "irrevocably waives, to the fullest extent permitted by applicable law,
any right it may
       have to a trial by jury in any suit, action or proceeding against the
depositary and/or
       [you]." We also note your disclosure on page 150 that "any legal suit,
action or
       proceeding against or involving us or the depositary... may only be
instituted in a state or
       federal court in New York, New York, and each [party] irrevocably waives
any objection
       which it may have to the laying of venue of any such proceeding, and
irrevocably submits
       to the exclusive jurisdiction of such courts in any such suit, action or
proceeding." Please
       confirm, if true, that the jury waiver and exclusive forum provisions
are not intended to
       apply to claims under the U.S. federal securities laws. With regards to
the exclusive forum
       provision, if it does not apply to actions arising under the Securities
Act or Exchange Act,
       please ensure that the exclusive forum provision in the deposit
agreement states this
       clearly, or tell us how you will inform investors in future filings that
the provision does
       not apply to any actions arising under the Securities Act or Exchange
Act. If the
       provisions do apply to claims under the U.S. federal securities laws,
please clearly
       disclose this in your filing and deposit agreement and provide risk
factor disclosure in
       your registration statement related to these provisions, including but
not limited to the
       enforceability of the provisions, increased costs to bring a claim,
limited access to
FirstName LastNameRichard imbalances of resources between the company and
shareholders,
       information and other Wei
Comapany that these provisions can discourage claims or limit shareholders
ability to bring a
       and NameECMOHO Ltd
July 24, 2019in a judicial forum that they find favorable.
       claim Page 4
FirstName LastName
 Richard Wei
FirstName LastNameRichard Wei
ECMOHO Ltd
Comapany NameECMOHO Ltd
July 24, 2019
July 24, 2019 Page 5
Page 5
FirstName LastName
Taxation, page 152

17.      Please ensure that the various opinions of counsel as to matters of
taxation are clearly
         identified as such, where applicable, in this section.
Notes to the Consolidated Financial Statements
1. Organization and Principal Activities
(a) Principal activities, page F-8

18.      We note your corporate structure in the diagram on page 61 that
includes your significant
         subsidiaries and VIE which appear to be inconsistent with your
disclosure of subsidiaries
         and VIE in Note 1 on page F-8. For example, certain entities such as
ECMOHO Co. Ltd.
         (Japan), Xianggui (Shanghai) Biotechnology Co., Ltd. (PRC), Shanghai
Hengcang Supply
         Chain Management Co., Ltd. (PRC), and Shanghai Yuyun Information
Technology Co.,
         Ltd. (PRC) are included in your corporate structure; however, they are
not presented in
         Note 1 on page F-8. Please revise the inconsistency in your
disclosure.
19.      We note your disclosure that the company is the primary beneficiary of
the VIE,
         Yibo. Please expand your disclosure to describe the terms of the
contractual agreements
         that gives the company through ECMOHO Shanghai power and economics
over Yibo.
20.      We note your disclosure that the VIE has an immaterial impact on the
consolidated
         financials of the Group. We also note your disclosure in the first
paragraph on page 62
         that your VIE, Yibo, holds the ICP licenses and other regulated
licenses and operates your
         internet-based business. In that regard, please disclose qualitative
information about
         involvement with the VIE, including the nature, purpose, size and
activities of the VIE.
         Please also include a description of the recognized and unrecognized
revenue-producing
         assets that are held by the VIE. These assets may include licenses,
trademarks, other
         intellectual property, facilities or assembled workforce. Refer to ASC
810-10-50-5A.d.
21.      Please disclose quantitative information for the VIE including
revenue; net income;
         operating, investing, and financing cash flows; and the carrying
amount and classification
         of the VIE's assets and liabilities, including intercompany payables
to ECMOHO
         Shanghai. Material related party transactions of the VIE should be
presented separately.
         Refer to paragraphs 5A.d., 2AA.d., and 3.bb of ASC 810-10-50.
2. Principal Accounting Policies
(i) Inventories, page F-13

22.      Please disclose the nature of cost elements included in inventory in
accordance with ASC
         210-10-S99-1(6)(b). Also, please tell us your consideration of
measuring your inventories
         at the lower of cost or net realizable value. Refer to ASC
330-10-35-1B.
 Richard Wei
FirstName LastNameRichard Wei
ECMOHO Ltd
Comapany NameECMOHO Ltd
July 24, 2019
July 24, 2019 Page 6
Page 6
FirstName LastName
(ad) Statutory reserves, page F-20

23.      We note that no statutory reserve was recorded as of December 31, 2017
and 2018.
         Please tell us and revise your disclosure to clarify why no statutory
reserve was recorded
         for the periods presented. Please also tell us whether your
subsidiaries in PRC had
         accumulated deficits in their functional currency, RMB, for the years
ended December 31,
         2017 and 2018.
(ai) Segment reporting, page F-21

24.      We note your disclosure on page 68 and elsewhere in your preliminary
prospectus that
         you market and distribute health supplements and food, mother and
child care products,
         personal care products, household healthcare equipment and other
health and wellness
         products. Please tell us your consideration of disclosing revenues for
each product and
         service or each group of similar products and services. Please refer
to ASC 280-10-50-40.
15. Redeemable non-controlling interests, page F-38

25.      Please disclose the expected redemption value as if it were currently
redeemable. See
         ASC 480-10-S99.
20. Income Taxes, page F-41

26.      We note you reversed $1,413,831 of your tax valuation allowance in
2018. Please provide
         us a detailed analysis that supports your determination of the tax
valuation allowance at
         December 31, 2018 including your basis for concluding that realization
of net deferred tax
         assets is more likely than not as required by ASC 740-10-30-5(e).
Please specifically
         address your assumptions regarding each source of taxable income
contemplated by ASC
         740-10-30-18. Further please revise your disclosure here or in
Critical Accounting
         Policies in Management's Discussion and Analysis of Financial
Condition and Results of
         Operations to provide a analysis of your assessment of the
realizability of your deferred
         tax assets as of December 31, 2018 and the reason for the significant
change in the
         valuation allowance from December 31, 2017. Refer to Item 303(a) of
Regulation S-K.
Item 8. Exhibits and Financial Statement Schedules
Exhibit 21.1, page II-3

27.      We note your disclosure of principle subsidiaries in Note 1 on page
F-8; as such, Qinghai
         Hengshoutang Plateau Medicine Co., Limited, Shanghai Jieshi Technology
Co., Limited
         and Yiling (Shanghai) Information Technology Co., Limited are not
presented in the list
         of significant subsidiaries per Exhibit 21.1. Please revise the
inconsistency in your
         disclosure or advise.
 Richard Wei
FirstName LastNameRichard Wei
ECMOHO Ltd
Comapany NameECMOHO Ltd
July 24, 2019
Page 7
July 24, 2019 Page 7
FirstName LastName
        You may contact Yolanda Guobadia at 202-551-3562 or Donna Di Silvio at
202-551-
3202 if you have questions regarding comments on the financial statements and
related
matters. Please contact Jennifer Lopez-Molina at 202-551-3792 or Mara Ransom at
202-551-
3264 with any other questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Consumer
Products