Mail Stop 3233
                                                                September 17,
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
                   Registration Statement on Form F-1
                   Filed September 7, 2018
                   File No. 333-227232

     Dear Mr. Andres:

            We have reviewed your 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 amending your registration
statement and providing the
     requested information. 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 any amendment to your registration statement and
the information you
     provide in response to these comments, we may have additional comments.

     Prospectus Summary

     Our Business, page 1

        1. We note the picture of the Studio City property. Please confirm that
the picture
           represents the current state of the property. To the extent the
picture represents the
           property, as anticipated upon completion of the hotel towers
described on page 30, please
           revise to clarify and disclose the anticipated cost of such
construction.

     Organizational Transactions, page 5

        2. Please revise the organizational chart to disclose the percentage of
Class A shares New
           Cotai may receive in exchange for its Participation Interest and
Class B shares.
 Geoffry P. Andres
Studio City International Holdings Limited
September 17, 2018
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        You may contact William Demarest, Staff Accountant, at (202) 551-3432
or Shannon
Sobotka, Staff Accountant, at (202) 551-3856 if you have questions regarding
comments on the
financial statements and related matters. Please contact Rahul K. Patel, Staff
Attorney, at (202)
551-3799 or me at (202) 551-3215 with any other questions.


                                                            Sincerely,

                                                            /s/ Kim McManus

                                                            Kim McManus
                                                            Senior Counsel
                                                            Office of Real
Estate and
                                                            Commodities

cc:     Jacqueline Wenchen Tang, Esq.