January 30, 2019 Richard Rixue Li Chief Executive Officer Secoo Holding Ltd 15/F, Building C, Galaxy SOHO Chaonei Street, Dongcheng District Beijing 100000 Re: Secoo Holding Ltd Form 20-F for the Fiscal Year Ended December 31, 2017 Filed April 26, 2018 File No. 001-38201 Dear Mr. Li: 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 Consumer Products cc: Z. Julie Gao, Esq., Skadden