December 4, 2018

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
           Form 6-K submitted March 23, 2018
           File No. 001-38201

Dear Mr. Li:

        We have limited our review of your filings to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 6-K submitted March 23, 2018

Reconciliations of GAAP and Non-GAAP Results, page Exh.99.1

1.    We note you have calculated adjusted net income (loss) per weighted
average shares
      based on net income/(loss) which adjusts for the losses attributable to
non-controlling
      interest, accretion to preferred shares and the related impact on the
number of shares
      outstanding. Further, the calculation is anti-dilutive. Your presentation
appears
      to substitute individually tailored measurement methods for those of
GAAP. See ASC
      260-10-45. Please also refer to the Division's Compliance & Disclosure
Interpretations,
      Non-GAAP Financial Measures updated April 4, 2018, Question 100.04.
Please revise
      your presentation to comply with Item 100(a) of Regulation G. This
comment also
      applies to Forms 6-K submitted on June 20, 2018 and September 6, 2018.
 Richard Rixue Li
Secoo Holding Ltd
December 4, 2018
Page 2

       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 Scott Stringer, Staff Accountant, at 202-551-3272 or
Donna Di Silvio,
Staff Accountant, at 202-551-3202 with any questions.



FirstName LastNameRichard Rixue Li                        Sincerely,
Comapany NameSecoo Holding Ltd
                                                          Division of
Corporation Finance
December 4, 2018 Page 2                                   Office of Consumer
Products
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