September 19, 2019

Mark White
Chief Executive Officer
One Horizon Group, Inc.
4300 Biscayne Boulevard, Suite 203
Miami, FL 33137

       Re: One Horizon Group, Inc.
           Registration Statement on Form S-1
           Filed on September 18, 2019
           File no. 333-233825

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 Paul Fischer at 202-551-3415 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Telecommunications
cc:    Laura Anthony