United States securities and exchange commission logo April 7, 2022 Cara Soffer General Counsel XpresSpa Group, Inc. 254 West 31st Street, 11th Floor New York, New York 10001 Re: XpresSpa Group, Inc. Registration Statement on Form S-3 Filed on March 31, 2022 File No. 333-264026 Dear Ms. Soffer: 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 Janice Adeloye at 202-551-3034 or Jennifer Lopez Molina at 202-551- 3792 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services