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                           December 23, 2020

       Michael Mathews
       Chief Executive Officer
       Aspen Group, Inc.
       276 Fifth Avenue, Suite 505
       New York, NY 10001

                                                        Re: Aspen Group, Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed December 18,
2020
                                                            File No. 333-251459

       Dear Mr. Mathews:

              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 Cara
Wirth at (202) 551-7127 with any questions.




                           Sincerely,


                           Division of Corporation Finance

                           Office of Trade & Services
       cc:                                              Michael D. Harris, Esq.