June 28, 2019

Herbert Ying Chiu Lee
Director and Chief Executive Officer
Integrated Media Technology Ltd
Level 7, 420 King William Street
Adelaide, SA 5000, Australia

       Re: Integrated Media Technology Ltd
           Form 20-F for the Year Ended December 31, 2018
           Filed May 15, 2019
           File No. 001-38018

Dear Mr. Lee:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 20-F for the Year Ended December 31, 2018

Risks Relating to our Organization
Our independent registered public accounting firm's audit documentation ... may
include audit
documentation located in China., page 15

1.    We note that your current auditor, Ramirez Jaminez International CPAS, is
based in Los
      Angeles, California but that the auditor's work papers are located in
China. We further
      note that although you are an Australian corporation, most of your
business operations are
      conducted in Hong Kong and the PRC. Please ask your US auditor the
following:

          why the audit work papers are located in China.
          whether the audit team physically conducted its field work in China
or relied upon the
          work of foreign auditors to complete their audit of the Company.
          if your auditor used the work of another firm, tell us the factors it
considered in not
          making reference to it. Refer to PCAOB AS 1205.04-05.
 Herbert Ying Chiu Lee
Integrated Media Technology Ltd
June 28, 2019
Page 2


Note 16. Intangible Assets and Goodwill, page F-24

2.       We note the key assumptions underlying the value in use of your cash
generating unit,
         including average growth rates of approximately 70% associated with
cash flows for years
         2 to 5 based on industry growth forecasts. Addressing IAS 36, please
tell us the
         following:

             whether the value in use reflects the present value of expected
future cash flows, that
             is, the weighted average of all possible outcomes. If not, tell us
why.
              how your 70% average growth rates relate to the 19.4% CAGR for
the global 3D
             display market (Source: Grand View Research Inc.) per your market
and industry
             analysis on page 33.
             what your growth rate assumptions are for projected cash flows
beyond the periods
             covered by the most recent budgets/forecasts.


       In closing, 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.

       You may contact Christie Wong, Staff Accountant, at (202) 551-3684 or
Kathryn
Jacobson, Senior Staff Accountant, at (202) 551-3365 with any questions.



FirstName LastNameHerbert Ying Chiu Lee                        Sincerely,
Comapany NameIntegrated Media Technology Ltd
                                                               Division of
Corporation Finance
June 28, 2019 Page 2                                           Office of
Telecommunications
FirstName LastName