June 25, 2019

Jianxin Zhang
Chief Executive Officer
China Liberal Education Holdings Limited
Huateng Century Park Headquarters
Building A, Level 2
Beijing, PRC

       Re: China Liberal Education Holdings Limited
           Amendment No. 1 to
           Draft Registration Statement on Form F-1
           Submitted June 18, 2019
           CIK No. 0001775085

Dear Mr. Zhang:

      We have reviewed your amended draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 1 to Draft Registration Statement on Form F-1

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Factors that Affect Our Results of Operations
Our Tuition and Service Fees Charged, page 39

1.     Highlight that the Chinese host universities you partner with for your
Sino-foreign jointly
       managed academic programs have the ability to withhold your portion of
tuition payments
       in certain circumstances. To the extent any such withholding may
materially affect your
       revenue, profitability, results of operations, or financial condition,
provide related risk
       factor disclosure.
 Jianxin Zhang
China Liberal Education Holdings Limited
June 25, 2019
Page 2
Our Ability to Control Costs and Expenses and Improve Our Operating Efficiency,
page 39

2.       Highlight that any costs related to teacher substitution, textbooks,
course materials and
         curriculums adjustment arising out of a service deficiency are borne
by the company
         rather than a host university.
Industry, page 56

3.       With regard to your statement that the information and data presented
in this section have
         been derived from the Frost & Sullivan industry report dated April
2019, indicate that the
         report was commissioned by the company in connection with this
offering.
        You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or
Robert S.
Littlepage, at (202) 551-3361 if you have questions regarding comments on the
financial
statements and related matters. Please contact Joshua Shainess,
Attorney-Adviser, at (202) 551-
7951 or Celeste M. Murphy, Legal Branch Chief, at (202) 551-3257 with any other
questions.



FirstName LastNameJianxin Zhang                      Sincerely,
Comapany NameChina Liberal Education Holdings Limited
                                                     Division of Corporation
Finance
June 25, 2019 Page 2                                 Office of
Telecommunications
FirstName LastName