October 23, 2024

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

       Re: Remark Holdings, Inc.
           Amendment No. 1 to Offering Statement on Form 1-A
           Filed October 15, 2024
           File No. 024-12515
Dear Kai-Shing Tao:

       We have reviewed your amended offering statement and have the following
comment.

       Please respond to this letter by amending your offering statement and
providing the
requested information. If you do not believe a comment applies 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 offering statement and the
information you
provide in response to this letter, we may have additional comments.

Amendment No. 1 to Offering Statement on Form 1-A
General

1.     We note your disclosure that you will file a Certificate of Designations
immediately
       prior to the first closing of this Offering, a copy of which will be
attached as Exhibit
       A. Please revise your disclosure to clarify when the initial closing of
this Offering will
       occur and when you are intending to file a Certificate of Designations.
Please note
       that Rule 251(d)(3)(i)(F) is limited to offerings that commence within
two calendar
       days after qualification and are made on a continuous basis during the
offering period
       and does not permit delayed offerings.
 October 23, 2024
Page 2

      Please contact Alexandra Barone at 202-551-8816 or Matthew Derby at
202-551-
3334 with any other questions.



                                                       Sincerely,

                                                       Division of Corporation
Finance
                                                       Office of Technology
cc:   Laura Holm, Esq.