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 FirstName LastName