April 16, 2020 Frank Cotroneo Chief Financial Officer Aspen Group, Inc. 276 Fifth Avenue, Suite 505 New York, New York 10001 Re: Aspen Group, Inc. Form 10-K for the Fiscal Year Ended April 30, 2019 Filed July 9. 2019 File No. 1-38175 Dear Mr. Cotroneo: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Trade & Services