October 10, 2018

Mark White
President and Chief Executive Officer
One Horizon Group, Inc.
34 South Molton Street
London W1K 5RG
United Kingdom

       Re: One Horizon Group, Inc.
           Registration Statement on Form S-3
           Filed October 9, 2018
           File No. 333-227760

Dear Mr. White:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

       Please contact William Mastrianna, Attorney-Adviser, at (202) 551-3778
with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Telecommunications
cc:    Vincent McGill