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                           February 22, 2021

       David Fischer
       General Counsel
       SPI Energy Co., Ltd.
       #1128, 11/F, No. 52 Hung To Road
       Kwun Tong
       Kowloon
       Hong Kong S.A.R.

                                                        Re: SPI Energy Co.,
Ltd.
                                                            Form F-3 Filed
February 18, 2021
                                                            File No. 333-253233

       Dear Mr. Fischer:

              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 Jeffrey
Gordon at 202-551-3866 with any questions.




                           Sincerely,


                           Division of Corporation Finance

                           Office of Manufacturing