October 3, 2019

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

       Re: ECMOHO Ltd
           Registration Statement on Form F-1
           Filed September 26, 2019
           FIle No. 333-233951

Dear Mr. Wei:

       We have reviewed your registration statement and have the following
comments. In
some of our comments, we may ask you to provide us with information so we may
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
circumstances or do not believe an amendment is appropriate, please tell us why
in your

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form F-1

Exhibit 5.1

1.     We note that in the legal opinion counsel opines that "there will be no
further obligation
       on the holder of any of the Class A Ordinary Shares to make any further
payment to the
       Company in respect of such Class A Ordinary Shares." Please have counsel
revise the
       legal opinion to also specify whether purchasers of the securities will
have any obligation
       to make payments or contributions to the registrant's creditors in
respect of the ordinary
       shares. For guidance, please refer to Section II.B.1.b and c of Staff
Legal Bulletin No. 19
       (Oct. 14, 2011).
 Richard Wei
October 3, 2019
Page 2
         Also, please have counsel revise its opinion to clarify the dual
nature of the offering
         and distinguish between the Class A ordinary shares being offered by
the company and
         the Class A ordinary shares being offered by the selling shareholders.

2.       We note your revised disclosures regarding a resale offering
component. Please confirm
         that such component relates only to the underwriter's over-allotment
option, as your
         disclosure suggests and revise the prospectus summary to disclose the
number and
         percentage of shares to be owned by the selling shareholders after the
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration

        You may contact Yolanda Guobadia, Staff Accountant, at (202) 551-3562
or Donna Di
Silvio, Staff Accountant, at (202) 551-3202 if you have questions regarding
comments on the
financial statements and related matters. Please contact Jennifer Lopez, Staff
Attorney, at (202)
551-3792 or Mara Ransom, Office Chief, at (202) 551-3720 with any other

FirstName LastNameRichard Wei                                 Sincerely,
Comapany NameECMOHO Ltd
                                                              Division of
Corporation Finance
October 3, 2019 Page 2                                        Office of Trade &
FirstName LastName