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                             October 7, 2022

       Kai-Shing Tao
       Chief Executive Officer
       Remark Holdings, Inc.
       800 S. Commerce St.
       Las Vegas, NV 89106

                                                        Re: Remark Holdings,
Inc.
                                                            Amendment No. 4 to
Registration Statement on Form S-1
                                                            Filed October 4,
2022
                                                            File No. 333-260615

       Dear Kai-Shing Tao:

             We have reviewed your amended 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.
Unless we note
       otherwise, our references to prior comments are to comments in our
August 31, 2022 letter.

       Amendment No. 5 to Registration Statement on Form S-1 filed October 4,
2022

       Cover Page

   1.                                                   We note your statement
that you do not have direct equity ownership of the VIEs. Please
                                                        revise this statement
here and throughout to clearly state that the company has no equity
                                                        ownership of any VIE.
Your revised disclosure should avoid the use of statements that
                                                        imply any indirect
ownership of any VIE.
 Kai-Shing Tao
FirstName  LastNameKai-Shing Tao
Remark Holdings, Inc.
Comapany
October    NameRemark Holdings, Inc.
        7, 2022
October
Page 2 7, 2022 Page 2
FirstName LastName
Prospectus Summary
Corporate Structure, page 2

2.       We note your statement on that you "expect to complete the transfer of
equity ownership
         of Remark Data Technology Co., Ltd. to the WFOE within a short period
of time." Please
         revise to provide a specific time period in which this acquisition of
ownership will be
         completed.
Entity Organizational Chart, page 4

3.       Please include an additional diagram illustrating your corporate
structure following the
         dissolution of the VIEs.
       Please contact Austin Pattan, Staff Attorney, at (202) 551-6756 or Jan
Woo, Legal
Branch Chief, at (202) 551-3453 with any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology
cc:      Robert Friedman