September 19, 2019

Scott L. Mathis
President & Chief Executive Officer
Gaucho Group Holdings, Inc.
135 Fifth Avenue, Floor 10
New York, NY 10010

       Re: Gaucho Group Holdings, Inc.
           Registration Statement on Form S-1
           Filed August 30, 2019
           File No. 333-233586

Dear Mr. Mathis:

       We have reviewed your registration statement 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.

Registration Statement on Form S-1 filed August 30, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Recent Developments and Trends, page 31

1.     We note your response to comment 5 and your revised disclosure,
including your
       statement that, by 2021/2022, you expect that your revenues from the
Gaucho line will
       represent a vast majority of your income, surpassing our wine and real
estate sales. Please
       balance your disclosure to provide that, for the reporting period, you
have not recognized
       any revenues from the Gaucho line of business and may not recognize any
revenues in the
       future.
2.     You state on page 32 that the quantitative and qualitative business and
industry data used
       in the section "is based on market research conducted on GGH's
behalf..." Please tell us
       whether you commissioned any third party research for use in connection
with this
 Scott L. Mathis
Gaucho Group Holdings, Inc.
September 19, 2019
Page 2
      offering. If so, please tell us what consideration you gave to filing the
third party's consent
      as an exhibit to the registration statement as required by Section 7 of
the Securities Act
      and Securities Act Rule 436. Alternatively, please revise your
disclosure, where
      applicable, to more clearly attribute the relevant disclosure to the
registrant.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        You may contact Peter McPhun, Staff Accountant, at (202) 551-3581 or
Kristina
Marrone, Staff Accountant, at (202) 551-3429 if you have questions regarding
comments on the
financial statements and related matters. Please contact Folake Ayoola, Senior
Counsel, at (202)
551-3673 or Erin E. Martin, Legal Branch Chief, at (202) 551-3391 with any
other questions.



                                                             Sincerely,

FirstName LastNameScott L. Mathis                            Division of
Corporation Finance
                                                             Office of Real
Estate and
Comapany NameGaucho Group Holdings, Inc.
                                                             Commodities
September 19, 2019 Page 2
cc:       Victoria Bantz
FirstName LastName