United States securities and exchange commission logo January 17, 2023 CERTIFIED MAIL RETURN RECEIPT REQUESTED Kevin Richard Benning Property General Manager Studio City International Holdings Ltd 36th Floor, The Centrium 60 Wyndham Street Central Hong Kong Re: Studio City International Holdings Ltd Amendment No. 1 to Registration Statement on Form F-3 Filed January 3, 2022 File No. 333-261406 Dear Kevin Richard Benning: It has been more than nine months since you last amended this registration statement and it is now out of date. Within 30 days from the date of this letter, you should either: amend it to comply with the applicable requirements of the Securities Act of 1933, the rules and regulations under the Act, and the requirements of the form; or file a request for withdrawal. If you requested confidential treatment for portions of any exhibits to your registration statement and you request withdrawal of that registration statement, please submit a concurrent request for withdrawal of your application for confidential treatment. If you do not amend the registration statement or file a request for withdrawal (or provide us with a satisfactory explanation of why you have not done either) within 30 days, we may enter an order declaring the registration statement abandoned under rule 479 of the Act. Please contact Maryse Mills-Apenteng at 202-551-3457 with any questions. Kevin Richard Benning Studio City International Holdings Ltd January 17, 2023 Page 2 FirstName LastNameKevin Richard Benning Sincerely, Comapany NameStudio City International Holdings Ltd Division of Corporation Finance January 17, 2023 Page 2 Office of Real Estate & Construction FirstName LastName