February 13, 2019

Tianhua Wu
Chief Executive Officer and Director
Up Fintech Holding LTD
18/F, Gandyvic Building, No. 1 Building,
No. 16 Taiyanggong Middle Road, Chaoyang District,
Beijing, 100020 PRC

       Re: Up Fintech Holding LTD
           Amendment No. 1 to
           Draft Registration Statement on Form F-1
           Submitted January 11, 2019
           CIK No. 0001756699

Dear Mr. Wu:

       We have reviewed your amended draft registration statement and have the
following
comment. In our comment, 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 comment applies 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 this comment
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted on
January 11, 2019

Note 9. Equity Interest with Preferential Rights, page F-31

1.     We note your response to comment 17, in which you state that the Company
would be
       required to re-measure the preferred shares to the redemption amount
when there is a
       more than remote chance that a Qualified IPO would not be completed.
Based on your
       response, it is not clear how the Company determined that there is only
a remote chance
       that a Qualified IPO would not be completed at each balance sheet date.
In this regard, we
       concur with your view, as provided in your correspondence, that the IPO
is not within the
       control of the Company. Please revise your accounting treatment to be
consistent with
 Tianhua Wu
Up Fintech Holding LTD
February 13, 2019
Page 2
      paragraphs 14 and 15 of ASC 480-10-S99-3A or explain, in sufficient
detail, how you
      determined that there is only a remote chance that a Qualified IPO would
not be
      completed at each balance sheet date given all of the factors that are
outside of the control
      of the Company.
       You may contact Stephen Kim at 202-551-3291 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jessica Livingston at 202-551-3448 or Pam Long at 202-551-3765 with any
other
questions.



                                                             Sincerely,
FirstName LastNameTianhua Wu
                                                             Division of
Corporation Finance
Comapany NameUp Fintech Holding LTD
                                                             Office of
Financial Services
February 13, 2019 Page 2
cc:       Ke Geng
FirstName LastName