November 20, 2018

Mark White
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 November 16, 2018
           File No. 333-228441

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 Gregory Dundas, Attorney Advisor, at (202) 551-3436 with
any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Telecommunications
cc:    Mark Orenstein, Esq.