Mail Room 3233
                                                             April 20, 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
               Draft Registration Statement on Form F-1
               Submitted March 23, 2018
               CIK No. 0001713334

Dear Mr. Andres:

      We have reviewed your amended draft 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 providing the requested information
and either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

General

1.     It appears you have submitted this registration statement confidentially
pursuant to the
       expanded nonpublic review process announced on June 29, 2017 and
supplemented on
       August 17, 2017. Please supplementally provide a cover letter confirming
that you will
       publicly file your registration statement and nonpublic draft
submissions at least 15 days
       prior to any road show, or in absence of a road show, at least 15 days
prior to the
       requested effective date of the registration statement.
 Geoffry P. Andres
Studio City International Holdings Limited
April 20, 2018
Page 2

Selected Consolidated Financial And Operating Data, page 65

2.      We note your exclusion of consolidated statements of operations data
for the year ended
        December 31, 2014 and consolidated balance sheet data for the year
ended December 31,
        2015. Please include this information within your amended filing and
revise your
        omission disclosure accordingly.

Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
69

3.      We note your disclosure throughout that, under the Services and Right
to Use Agreement,
        the Gaming Operator deducts gaming tax and the costs incurred in
connection with its
        operations from gross gaming revenues and the company receives the
residual amount.
        However, it appears that the Operator Consideration must also be paid
under the
        Agreement. Please also revise your disclosure throughout to more
clearly discuss the
        terms of the Services and Right to Use Agreement. Please also revise
your disclosure
        here and elsewhere to discuss in greater detail the Operator
Consideration in the Services
        and Right to Use Agreement.

Note 2. Summary of Significant Accounting Policies

(n) Revenue Recognition, page F-13

4.      Please clarify whether the fee to the Gaming Operator under the
Services and Rights to
        Use Arrangements represents only cost reimbursement or if there is a
fee beyond
        reimbursement of costs and how that fee is determined.

5.      Please tell us why some or all of the Services and Rights to Use
Arrangements are not in
        the scope of ASC 840.

Recent Accounting Standards not yet adopted, page F-15

6.      We note your response to our prior comment 11. Please clarify how you
account for the
        expense of complementary services and how these expenses will be
accounted for upon
        the adoption of the new revenue standard.

14. Related Party Transactions, page F-30

7.      Please explain why Melco and its subsidiaries constituted 55% and 49%
of rooms and
        food and beverage revenues for the years ended December 31, 2017 and
2016.
 Geoffry P. Andres
Studio City International Holdings Limited
April 20, 2018
Page 3

       You may contact William Demarest, Accountant at 202-551-3432 or Shannon
Sobotka,
Accountant at 202-551-3856 if you have questions regarding comments on the
financial
statements and related matters. Please contact Rahul Patel, Attorney at
202-551-3799 or me at
202-551-3655 with any other questions.


                                                          Sincerely,

                                                          /s/ Sonia Gupta
Barros

                                                          Sonia Gupta Barros
                                                          Assistant Director
                                                          Office of Real Estate
&
                                                          Commodities

cc:     Jacqueline Wenchen Tang, Esq.