Mail Stop 3233

                                                                October 16,
2018

     Via E-mail
     Geoffry P. Andres
     Property President
     Studio City International Holdings Limited
     36/F, The Centrium
     60 Wyndham Street
     Hong Kong

            Re:    Studio City International Holdings Limited
                   Amendment No. 1 to Registration Statement on Form F-1
                   Filed October 9, 2018
                   File No. 333-227232

     Dear Mr. Andres:

           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
September 17, 2018 letter.

     Unaudited Pro Forma Condensed Consolidated Balance Sheet, page 81

        1. Please tell us how you determined it was unnecessary to reflect the
sale of the ADSs
           within your pro forma financial statements. Reference is made to
Rule 11.01 of
           Regulation S-X.
 Geoffry P. Andres
Studio City International Holdings Limited
October 16, 2018
Page 2

        You may contact William Demarest, Staff Accountant, at (202) 551-3432
or Shannon
Sobotka, Staff Accountant, at (202) 551-3856 if you have questions regarding
comments on the
financial statements and related matters. Please contact Rahul K. Patel, Staff
Attorney, at (202)
551-3799 or me at (202) 551-3215 with any other questions.


                                                            Sincerely,

                                                            /s/ Kim McManus

                                                            Kim McManus
                                                            Senior Counsel
                                                            Office of Real
Estate and
                                                            Commodities

cc:     Jacqueline Wenchen Tang, Esq.