Mail Stop 3561
                                                           September 27, 2018


Mr. Brent Y. Suen
Chief Executive Officer
Weyland Tech, Inc.
85 Broad Street, 16-079
New York, NY 10004

        Re:      Weyland Tech, Inc.
                 Amendment No. 1 to Form 10-K for Fiscal Year Ended December
31, 2016
                 Filed September 12, 2018
                 Form 10-Q for Fiscal Quarter Ended June 30, 2018
                 Filed August 14, 2018
                 File No. 000-51815

Dear Mr. Suen:

       We have reviewed your filings 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 March 6,
2018 letter.

Form 10-K for Fiscal Year Ended December 31, 2016, as amended

Item 9A. Controls and Procedures, page 3

    1. We note your revised disclosure that your Chief Executive Officer and
Chief Financial
       Officer concluded your disclosure controls and procedures were effective
as of December
       31, 2016. However, the disclosure in your original Form 10-K implied
that your
       disclosure controls and procedures were not effective as of December 31,
2016, and you
       confirmed to us in your response dated April 11, 2018 to comment 3 in
our March 6,
       2018 comment letter that your management concluded your disclosure
controls and
       procedures were not effective as of December 31, 2016. Please file a
further amendment
       to your December 31, 2016 Form 10-K to revise your Disclosure Controls
and
 Mr. Brent Suen
Weyland Tech, Inc.
September 27, 2018
Page 2

       Procedures conclusion to be consistent with your April 11, 2018 response
or advise us in
       detail why you believe no such revision is required.

    2. We note that in your revised Management's Report on Internal Control
over Financial
       Reporting your management concluded that your internal controls over
financial
       reporting were effective as of December 31, 2016. However, the
disclosure in your
       original Form 10-K indicated that you had identified material weaknesses
in your internal
       controls over financial reporting as of December 31, 2016, and you
confirmed to us in
       your response dated April 11, 2018 to comment 3 in our March 6, 2018
comment letter
       that your management concluded your internal controls over financial
reporting were not
       effective as of December 31, 2016. Please file a further amendment to
your December
       31, 2016 Form 10-K to revise your Management's Report on Internal
Control over
       Financial Reporting to be consistent with your April 11, 2018 response
or advise us in
       detail why you believe no such revision is required.

Form 10-Q for the Fiscal Quarter Ended June 30, 2018

Item 4. Controls and Procedures, page 22

    3. We note your disclosure that as of the end of the period covered by this
Annual Report on
       Form 10-K, your Chief Executive Officer and Chief Financial Officer
performed an
       evaluation of the effectiveness of your disclosure controls and
procedures and based on
       this evaluation they concluded that your disclosure controls and
procedures were
       effective as of December 31, 2017. We further note your disclosure on
page 23 that there
       were no changes in your internal control over financial reporting that
occurred during the
       quarter ended December 31, 2017 that have materially affected your
internal control over
       financial reporting. These disclosures do not satisfy the requirements
of Item 4 to Part I
       of Form 10-Q since they do not provide the information required by Item
307 and Item
       308(c) of Regulation S-K as of the quarter end. Please amend your Form
10-Q to provide
       these disclosures as of June 30, 2018. Additionally, please confirm to
us that all future
       interim reports will provide management's conclusion regarding the
effectiveness of your
       disclosure controls and procedures and will disclose whether any changes
occurred in
       your internal control over financial reporting that materially affected
your internal control
       over financial reporting as of the quarter end.
 Mr. Brent Suen
Weyland Tech, Inc.
September 27, 2018
Page 3

      You may contact Sondra Snyder, Staff Accountant at (202) 551-3332 or me,
at (202)
551-3737 with any questions.


                                                        Sincerely,

                                                        /s/ Jennifer Thompson

                                                        Jennifer Thompson
                                                        Accounting Branch Chief
                                                        Office of Consumer
Products