Mail Stop 4561

                                                            December 4, 2019

Sing Wang
Chief Executive Officer
TKK Symphony Acquisition Corporation
c/o Texas Kang Kai Capital Management (Hong Kong) Limited
2039, 2/F United Center
95 Queensway Admiralty, Hong Kong

       Re:    TKK Symphony Acquisition Corporation
              Amendment No. 2 to Schedule TO-I filed November 22, 2019
              Filed by TKK Symphony Acquisition Corporation
              File No. 005-90609

Dear Mr. Wang:

        We have reviewed the above-captioned filing, and have the following
comments. Where
indicated, the Schedule TO should be amended in response to these comments. If
you disagree,
we will consider the explanation as to why a comment is inapplicable or a
revision is not
necessary. In some of our comments, we may ask for information so we may better
understand
your disclosure. After reviewing this information, we may raise additional
comments.

        Please understand that the purpose of our review process is to assist
you in your
compliance with the applicable disclosure requirements and to enhance the
overall disclosure in
your filing. We look forward to working with you in these respects. We welcome
any questions
you may have about our comments or any other aspect of our review. Unless
otherwise noted,
where prior comments are referred to they refer to our letter dated November 8,
2019.

Management's Discussion and Analysis of Financial Condition and Results of
Operations of
Glory Star Group, page 124

1.     We note your response to prior comment number 9. Please tell us whether
management
       uses the number of either daily active users or monthly active users to
manage the
       business. In this regard, we note your disclosure on pages 130-131 that
the growth of
       your live shows has attracted numerous active users to provide a
platform for more
       advertisers.

Notes to Consolidated Financial Statements, page F-38

2.     In regard to your response to our comment three, tell us how you
determined that your
       "net restricted net assets were 4.2 percent of the consolidated equity
as of December 31,
 Sing Wang
TKK Symphony Acquisition Corp.
December 4, 2019
Page 2

       2018." Tell us how you considered your statements to comments two and
ten where you
       state, "Glory Star is a holding company with no material operations of
its own. Glory Star
       conducts its operations primarily through its subsidiaries and VIEs in
China. As a result,
       Glory Star's ability to pay dividends depends upon dividends paid by
Glory Star's
       wholly-owned subsidiaries. In addition, Glory Star's WFOE is permitted
to pay dividends
       to us only out of their retained earnings, if any, as determined in
accordance with PRC
       accounting standards and regulations... Remittance of dividends by a
wholly foreign-
       owned company out of China is subject to examination by the banks
designated by the
       SAFE." Furthermore, tell us how you considered your new disclosure noted
in your
       response to comment one where you state, "we need to obtain SAFE
approval to use cash
       generated from the operations of the WFOE and VIE to pay off their
respective debt in a
       currency other than Renminbi owed to entities outside China, if any, or
to make other
       capital expenditure payments outside China in a currency other than
Renminbi. The PRC
       government may at its discretion restrict access to foreign currencies
for current account
       transactions in the future."

2. Summary of Significant Accounting Policies

(m) Revenue Recognition, page F-44

3.     We note your response to prior comment 13. Please clarify the measure of
progress used
       to recognize copyright revenue associated with content that you
co-produce with others.
       For example, it is unclear if you recognize over time based upon the
number of views and
       unit price per view, based upon an allocation of transaction price as
each episode is
       delivered or some other method. Please refer to ASC 606-10-25-31 through
25-34 and
       606-10-50-18.

General

4.     We note your response to prior comment 17. In order to provide context
to your claims
       that you "operate a leading mobile and online advertising, digital
media, and
       entertainment business in China" and that you have a "leading market
position" please
       provide quantitative disclosure, such as market size and your market
share, with respect
       to each of your business lines.

5.     As represented in the correspondence dated November 8, 2019, and
submitted
       electronically on EDGAR by TKK on the same date, please confirm that the
Exhibit
       Index to Schedule TO will be amended to explicitly include the periodic
reports which
       have been incorporated by reference by TKK in response to Item 10 of
Schedule TO.
 Sing Wang
TKK Symphony Acquisition Corp.
December 4, 2019
Page 3

        You may contact Inessa Kessman, Staff Accountant, at (202) 551-3371, or
Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361, if you have questions
regarding comments
on the financial statements and related matters. Please contact Jeff Kauten,
Attorney-Advisor, at
(202) 551-3447, or in his absence, Larry Spirgel, Office Chief, at (202)
551-3815, with any other
questions.

                                                           Sincerely,

                                                           /s/ Nicholas P.
Panos

                                                           Nicholas P. Panos
                                                           Senior Special
Counsel
                                                           Office of Mergers &
Acquisitions

cc: Douglas S. Ellenoff, Esq.
Stuart Neuhauser, Esq.
Jeffrey W. Rubin, Esq.
Joshua N. Englard, Esq.
Ellenoff Grossman & Schole LLP