November 20, 2018 Mark White Chief Executive Officer One Horizon Group, Inc. 34 South Molton Street London W1K 5RG United Kingdom Re: One Horizon Group, Inc. Registration Statement on Form S-3 Filed November 16, 2018 File No. 333-228441 Dear Mr. White: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Gregory Dundas, Attorney Advisor, at (202) 551-3436 with any questions. Sincerely, Division of Corporation Finance Office of Telecommunications cc: Mark Orenstein, Esq.