December 14, 2018

Xiaodong Chen
Blue Hat Interactive Entertainment Technology
7th Floor, Building C, No. 1010 Anling Road
Huli District, Xiamen, China

       Re: Blue Hat Interactive Entertainment Technology
           Draft Registration Statement on Form F-1
           Submitted November 19, 2018
           CIK No: 0001759136

Dear Mr. Chen:

       We have reviewed your draft registration statement and have the
following comments. In
some of our comments, we may ask you to provide us with information so we may
understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional

Form F-1 DRS


1.     Please provide us with copies of all written communications, as defined
in Rule 405 under
       the Securities Act, that you, or anyone authorized to do so on your
behalf, present to
       potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they
       retain copies of the communications.
2.     Please provide us with copies of any additional graphics, maps,
photographs, and related
       captions or other artwork including logos that you intend to use in the
prospectus. Please
       keep in mind, in scheduling printing and distributing of the preliminary
prospectus, that
       we may have comments after reviewing the materials.
 Xiaodong Chen
Blue Hat Interactive Entertainment Technology
December 14, 2018
Page 2
There can be no assurance that we will not be a passive foreign investment
company, page 36

3.       Please reconcile your disclosure here that you "do not presently
expect to be a PFIC for
         the current taxable year or the foreseeable future" with your
disclosure on page 104 that
         "we expect to be a PFIC for our current taxable year" and "believe
that we likely will be a
         PFIC under the PFIC income test in future taxable years as well."
Contractual Arrangements, page 46

4.       Please revise your discussion of the Exclusive Business Cooperation
Agreement to further
         describe the adjustment of the service fee paid to Blue Hat WFOE.
Explain under what
         conditions it may be adjusted and by which party.
Our Strategy, page 75

5.       We note your disclosure here that you intend to open or franchise 50
to 100 additional
         stores in 2019 to increase your physical presence in China and over
the next 3 years
         you plan to open or franchise approximately 500 science and experience
stores across
         China. Please discuss the material steps and costs involved with such
endeavors, and
         disclose the challenges and risks involved with this expansion
strategy. In describing
         these trends in your liquidity and capital resources discussion,
disclose the
         estimated amounts of capital that will be required, to the extent
        You may contact Heather Clark at 202-551-3624 or Melissa Raminpour at
if you have questions regarding comments on the financial statements and
matters. Please contact John Stickel at 202-551-3324 or John Dana Brown at
202-551-3859 with
any other questions.

FirstName LastNameXiaodong Chen                       Sincerely,
Comapany NameBlue Hat Interactive Entertainment Technology
                                                      Division of Corporation
December 14, 2018 Page 2                              Office of Transportation
and Leisure
FirstName LastName