April 25, 2019

Leonard Fluxman
Executive Chairman
OneSpaWorld Holdings Ltd
H & J Corporate Services Ltd.
Ocean Centre, Montagu Foreshore
East Bay Street
P.O. Box SS - 19084
Nassau, New Providence, Bahamas

       Re: OneSpaWorld Holdings Ltd
           Registration Statement on Form S-1
           Filed April 18, 2019
           File No. 333-230950

Dear Mr. Fluxman :

       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 Patrick Kuhn at (202) 551-3308 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Transportation and Leisure