September 17, 2019

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

       Re: ECMOHO Ltd
           Amendment No.1 to Draft Registration Statement on Form F-1
           Filed August 30, 2019
           CIK 0001763197

Dear Mr. Wei:

      We have reviewed your amended draft registration statement and have the
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

Amendment No. 1 to Draft Registration Statement on Form F-1

Risk Factors
ADSs holders may not be entitled to a jury trial with respect to claims arising
under the deposit
agreement...,, page 53

1.     Please remove the reference to ``substantive   provisions of the U.S.
federal securities
       laws in the last sentence of this risk factor disclosure.
 Richard Wei
FirstName LastNameRichard Wei
Comapany 17, 2019
September NameECMOHO Ltd
September 17, 2019 Page 2
Page 2
FirstName LastName
Your rights to pursue claims against the depositary as a holder of ADSs are
limited by the terms
of the deposit agreement...,, page 53

2.       We note your revisions in response to comment 16 and we reissue the
comment in-part.
         Please revise this section, as you did in your waiver of jury trial
risk factor, to clearly
         disclose related risks, including but not limited to increased costs
to bring a claim, and that
         the provision can discourage claims or limit shareholders' ability to
bring a claim in a
         judicial forum that they find favorable.

         As a related matter, please confirm that the deposit agreement, when
filed, will disclose
         that the exclusive forum and waiver of jury trial provisions apply to
actions arising under
         the Securities Act and Exchange Act.
Brand Partner Development and Services, page 105

3.       We note your response to prior comment 13 and your revised disclosure
that "five of the
         ten largest brand partners in terms of revenue contribution in the six
months ended
         June 30, 2019 are under the common control of a global food and
beverage company." We
         also note your response that it is your view that pursuant to Item
601(b)(10)(ii) of
         Regulation S-K, these agreements are not required to be filed as
"[e]ach of these brand
         partners is managed by its own dedicated operations team that make
their own decisions
         independently from each other regarding the selection of
distributors." Please provide
         additional information regarding the relationship among these brand
partners in support of
         your response, as your disclosure in this section suggests that the
common control among
         these brand partners has affected your business partnerships. In this
regard, your
         disclosure on page 106 states that "[w]hile the partnership
relationships were developed
         independently, we believe the trust developed through existing
partnerships has been
         conducive to further partnerships with other brands owned by this
company." For
         example, tell us how failure to maintain a satisfactory relationship
with one affiliate brand
         partner could affect your relationship with other brand partners under
common control and
         what consideration you have given to assessing your substantial
dependence upon these
         arrangements in the aggregate, given the common control.

2. Principal Accounting Policies
(i) Inventories, page F-13

4.       We reviewed your response to comment 22 and the revisions to your
disclosure. Please
         revise your disclosure to clarify that inventory is stated at the
lower of cost or net
         realizable value pursuant to ASC 330-10-35-1B, as previously
requested. A similar
         revision should be made to your critical accounting policies
disclosure on page 80.
 Richard Wei
September 17, 2019
Page 3

        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, Assistant Director, at 202-551-3264 with any other

FirstName LastNameRichard Wei                               Sincerely,
Comapany NameECMOHO Ltd
                                                            Division of
Corporation Finance
September 17, 2019 Page 3                                   Office of Consumer
FirstName LastName