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                                                           December 20, 2018

Yingmei Yang
Interim Chief Financial Officer
Lianluo Smart Limited
Room 2108, 21st Floor
China Railway Construction Building
No. 20 Shijingshan Road, 100040, Beijing, China

       Re: Lianluo Smart Limited
           Form 20-F for the Fiscal Year Ended December 31, 2017
           Filed April 25, 2018
           File No. 001-34661

Dear Ms. Yang:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 20-F for the Fiscal Year Ended December 31, 2017

Item 3. Key Information
A. Selected Financial Data, page 2

1.    We note that you only presented selected financial data for the years
ended December 31,
      2015, 2016 and 2017 instead of the required five most recent financial
years, and you did
      not explain the reasons for the omission in the filing. Tell us why you
have not provided
      five years of data and revise future filings to comply fully with Item
3(A) of Form 20-F
      and the related instructions.
 Yingmei Yang
FirstName LastNameYingmei Yang
Lianluo Smart Limited
Comapany20, 2018
December NameLianluo Smart Limited
December 20, 2018 Page 2
Page 2
FirstName LastName
Item 5. Operating and Financial Review Prospects
Critical Accounting Policies
Inventories, page 60

2.       We note that management compares the cost of inventories with their
net realizable value
         and an allowance is recorded to write down the inventories to market
value, if lower. We
         also note that from your disclosures on page F-22 that you recorded a
$73,860 inventory
         write-down reversal during the year ended December 31, 2017. Please
address the
         following:

              Clarify for us whether your inventory is written down to market
value or to net
             realizable value and explain to us how your policy is consistent
with ASU 2015-11
             which requires that inventory within the scope of the guidance be
measured at the
             lower of cost and net realizable value. Revise your disclosures in
future filings to
             reflect compliance with ASU 2015-11.

             Describe to us the circumstances that led to the inventory
write-down reversal in fiscal
             2017 and explain to us how you considered FASB ASC 330-10-35-14
and SAB Topic
             5.BB in your accounting.

             Tell us whether you recorded any sales of previously written-down
inventory in the
             reported periods, and if material, revise your discussion of
operating results in future
             filings to quantify and discuss the impact on your gross margins.
3.       We note the significant increase in your inventory at December 31,
2017. Please address
         the following:

             Tell us the specific methodology you employed to assess inventory
for impairment at
             December 31, 2017, including a description of the key assumptions
and your basis for
             those assumptions, and explain your basis for concluding that the
carrying value of
             your inventory is recoverable.

             Revise this section in future filings to discuss the significant
judgments and
             uncertainties involved in your accounting for inventory.
Report of Independent Registered Public Accounting Firm, page F-2

4.       We note that your financial statements for the year ended December 31,
2016 were
         restated due to an error in the accounting treatment of warrants
issued. Please have your
         auditor explain to us how it considered paragraphs .09, .16 and .17 of
PCAOB Auditing
         Standard 2820 regarding the addition of an explanatory paragraph to
its report concerning
         the restatement.
 Yingmei Yang
Lianluo Smart Limited
December 20, 2018
Page 3
Note 4 - Summary of Significant Accounting Policies
Revenue Recognition, page F-15

5.       On page 33 you disclose that you are a significant distributor in
China for laryngcopes
         from Timesco Healthcare Ltd. Additionally on page F-10 you disclose
that you have the
         distribution rights for a number of international medical equipment
suppliers. Please
         address the following:

             Describe to us the arrangements under which you undertake to be
the distributor of
             another company's products, and summarize for us the material
terms of the
             agreements governing these arrangements.

             Tell us whether you are the principal or agent in these
transactions and explain how
             you made that determination.

             Revise your future filings to disclose your revenue recognition
policy related to
             transactions in which you act as a distributor.
       In closing, 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.

      You may contact Eric Atallah at (202)-551-3663 or Martin James, Senior
Assistant Chief
Accountant, at (202) 551-3671 with any questions.



FirstName LastNameYingmei Yang                                 Sincerely,
Comapany NameLianluo Smart Limited
                                                               Division of
Corporation Finance
December 20, 2018 Page 3                                       Office of
Electronics and Machinery
FirstName LastName
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