March 26, 2020

Via E-mail

Z. Julie Gao, Esq.
Skadden, Arps, Slate, Meagher & Flom
c/o 42/F, Edinburgh Tower, The Landmark
15 Queen's Road Central
Hong Kong


       Re:      Jumei International Holding Limited
                Amendment No. 1 to Schedule TO-T/13E-3
                Filed March 20, 2020 by Jumei Investment Holding Limited, Super
ROI
                       Global Holding Limited, and Leo Ou Chen
                File No. 005-88610

Dear Ms. Gao:

       The staff in the Office of Mergers and Acquisitions has reviewed your
amended filings.
We have the comments set forth below. 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 filing, by providing the
requested
information, or by advising us when you will provide the requested response. 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 amendments to your filings and the information you
provide in
response to these comments, we may have additional comments.

General

1. We note your response to prior comment 1. Please ensure that you jointly
"tag" the Schedule
   TO-T as a Schedule 13E-3 filing in your amended Schedule TO so that the
EDGAR system
   reflects its status as both a Schedule TO and 13E-3 as to each filer.

2. We note your response to comment 2 but are unable to agree with your
analysis.
 Z. Julie Gao, Esq.
Skadden, Arps, Slate, Meagher & Flom
March 26, 2020
Page 2

3. Notwithstanding your assertion in response to comment 3 that neither Parent
nor Purchaser is
   an "independent entity" separate from Mr. Chen, we continue to believe that
a group was
   formed and that disclosure of the existence of the group is required. Rule
13d-5 does not
   provide for any distinction or exceptions based upon a person or entity's
independence from
   another person. Additionally, we believe the parties' joint filing agreement
provides support
   for our view that the parties should file an amended Schedule 13D reflecting
group status.

Schedule TO-T   Exhibit (a)(1)(i)   Offer to Purchase for Cash
Conditions to the Offer

4. We note your response to comment 18. In your amended filing, please add the
disclosure
   included in your response letter regarding Mr. Chen's undertaking that he
will not cause the
   Company or any of its affiliates to deliberately breach the agreements or
obligations under
   the Merger Agreement.


                                              *   *   *

        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

        Please direct any questions to me at (202) 551-7951. You may also
contact Tina Chalk,
Senior Special Counsel, at (202) 551-3263.


                                                            Sincerely,

                                                            /s/ Joshua Shainess

                                                            Joshua Shainess
                                                            Special Counsel
                                                            Office of Mergers
and Acquisitions