September 19, 2019

Tim Ti
Chief Executive Officer
UTStarcom Holdings Corp.
Level 6, 28 Hennessy Road,
Admiralty, Hong Kong

       Re: UTStarcom Holdings Corp.
           Form 20-F for the Year Ended December 31, 2018
           Filed April 17, 2019
           File No. 001-35216

Dear Mr. Ti:

      We have reviewed your filing 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 comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 20-F for the Year Ended December 31, 2018

Notes to the Consolidated Financial Statements
Note 15. Credit Risk and Concentration, page F-32

1.    We note your accounts receivable increased significantly as of December
31, 2018, to $60
      million, with one major customer representing 93% of this balance. Please
tell us the
      extent of your subsequent collection of this accounts receivable balance.
Also, please tell
      us and disclose in future filings the repayment terms granted to this
customer and whether
      the accounts receivable are financing receivables.
        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.
 Tim Ti
UTStarcom Holdings Corp.
September 19, 2019
Page 2

        You may contact Robert Shapiro, Senor Staff Accountant, at (202)
551-3273 or Robert S.
Littlepage, Accounting Branch Chief, at (202) 551-3361, if you have questions
regarding
comments on the financial statements and related matters.



FirstName LastNameTim Ti                                  Sincerely,
Comapany NameUTStarcom Holdings Corp.
                                                          Division of
Corporation Finance
September 19, 2019 Page 2                                 Office of
Telecommunications
FirstName LastName