October 31, 2019 Guangjie Jin Chief Executive Officer Q&K International Group Limited Suite 1607, Building A No.596 Middle Longhua Road Xuhui District, Shanghai, 200032 People's Republic of China Re: Q&K International Group Limited Amendment No. 1 to Registration Statement on Form F-1 Filed October 25, 2019 File No. 333-234112 Dear Mr. Jin: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our October 16, 2019 letter. Form F-1 filed October 25, 2019 General 1. We note your response to prior comment 2 that the price adjustments are excluded from the average monthly rental or the average monthly rental before discount for rental prepayments. We further note the definitions of average monthly rental and average monthly rental before discount for rental prepayments on page 8 as well as your disclosure regarding your marketing expenses and promotion costs on pages 99 and 100. Please confirm to us that the average monthly rental and average monthly rental before discount for rental prepayments amounts on pages 17 and 96 reflect all promotion costs or revise Guangjie Jin Q&K International Group Limited October 31, 2019 Page 2 accordingly. In addition, please tell us the nature of the promotion costs that are included in the selling and marketing expenses described on page 100. You may contact Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. Please contact Maryse Mills-Apenteng at 202-551-3457 or Jennifer Gowetski at 202-551-3401 with any other questions. Sincerely, FirstName LastNameGuangjie Jin Division of Corporation Finance Comapany NameQ&K International Group Limited Office of Real Estate & Construction October 31, 2019 Page 2 cc: Shuang Zhao, Esq. FirstName LastName