June 3, 2019 Jie Yu Chief Financial Officer Luokung Technology Corp. LAB 32, SOHO 3Q, No 9, Guanghua Road Chaoyang District Beijing People's Republic of China, 100020 Re: Luokung Technology Corp. Supplemental Response dated May 23, 2019 Registration Statement on Form F-3 File No. 333-231127 Dear Mr. Yu: We have reviewed your supplemental response and have the following comment. Our reference to a prior comment is to a comment in our May 17, 2019 letter. Please respond to this letter by amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to this comment, we may have additional comments. Supplemental Response dated May 23, 2019 General 1. Your response to prior comment 2 indicates that arbitration is intended to be the exclusive means for resolving matters with your shareholders and that the arbitration provision is intended to apply to claims made under U.S. federal securities laws. Please revise your Description of Share Capital section to fully describe the provision and add risk factor disclosure regarding how this provision impacts your shareholders, including: a description of the relevant forum for arbitration; any question as to the enforceability of this provision; a statement that arbitration is intended to be the exclusive means for resolving matters Jie Yu Luokung Technology Corp. June 3, 2019 Page 2 with your shareholders and that the provision is intended to apply to claims made under the U.S. federal securities laws and the rules and regulations; and a statement that investors cannot waive the company's compliance with federal securities laws and the rules and regulations promulgated thereunder. Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or, in his absence, Jan Woo, Legal Branch Chief, at (202) 551-3453 with any questions. Sincerely, FirstName LastNameJie Yu Division of Corporation Finance Office of Information Technologies Comapany NameLuokung Technology Corp. and Services June 3, 2019 Page 2 cc: William N. Haddad, Esq. FirstName LastName