December 13, 2018

VIA EDGAR

Donna Di Silvio, Staff Accountant

Scott Stringer, Staff Accountant

Office of Consumer Products

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:                             Secoo Holding Limited (the “Company”)

Form 20-F for the Fiscal Year Ended December 31, 2017 (the “2017 Form 20-F”) Filed on April 26, 2018

Form 6-K Submitted March 23, 2018 (the “Form 6-K”)

File No. 001-38201

Dear Mr. Stringer and Ms. Di Silvio:

This letter sets forth the Company’s response to the comment contained in the letter dated December 4, 2018 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the Company’s 2017 Form 20-F and Forms 6-K. The Staff’s comment is repeated below and is followed by the Company’s response thereto. All capitalized terms used but not defined in this letter shall have the meanings ascribed to such terms in the 2017 Form 20-F or Forms 6-K.

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.

The Company respectfully advises the Staff that the Company utilize net income/loss for Non-GAAP net income/(loss) per weighted average shares considering: (i) loss attributable to non-controlling interest and accretion to redeemable non-controlling interest is immaterial for all the periods presented; (ii) all the Company’s preferred shares were automatically converted into ordinary shares upon the completion of Company’s initial public offering on September 22, 2017 and there was no preferred shares nor accretion to preferred shares since September 22, 2017; and (iii) the Company is in the view that the Non-GAAP net income/(loss) per weighted average shares, without adjustment of the losses attributable to non-controlling interest and accretion to preferred shares, would better reflect the actual business results and changes when comparing the current and prior periods.

The Company further advises the Staff that the differences of Non-GAAP net income (loss) and Non-GAAP net income (loss) attributed to ordinary shareholders per weighted average shares for the quarters ended December 31, 2017, March 31, 2018, June 30, 2018 and September 30, 2018, are as below:

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In response to the Staff’s comment, the Company will revise the disclosure to utilize the net income attributable to ordinary shareholders for the calculation of the Non-GAAP earnings per share in  future Form 6-K submitted to the SEC.

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If you have any additional questions or comments regarding the 2017 Form 20-F or Form 6-K, please contact the undersigned at (8610) 6588-0135 or the Company’s U.S. counsel, Z. Julie Gao of Skadden, Arps, Slate, Meagher & Flom LLP, at (852) 3740-4863, respectively. Thank you very much.

cc:                                Richard Rixue Li, Chairman and Chief Executive Officer, Secoo Holding Limited
Shaojun Chen, Chief Financial Officer, Secoo Holding Limited

Z. Julie Gao, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP

Haiping Li, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP

Allen Lu, Partner, KPMG Huazhen LLP

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