May 17, 2022




Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Janice Adeloye
  Jennifer Lopez Molina


XpresSpa Group, Inc.

Pre-Effective Amendment No. 1 to Registration Statement on Form S-3

Filed May 17, 2022

(Commission File No. 333-264026)


Dear Sir or Madam:


In accordance with Rule 461 under the Securities Act of 1933, as amended, XpresSpa Group, Inc. (the “Company”) hereby requests that the Registration Statement referred to above be declared effective Thursday, May 19, 2021 at 4:30 p.m. E.T. or as soon thereafter as shall be practicable.


Very truly yours,  
/s/ Cara Soffer  
By: Cara Soffer  
  General Counsel and Secretary  


cc:   James A. Berry, Chief Financial Officer