SecProbe.io

April 22, 2020
LiMing Yung
Chief Financial Officer
Pingtan Marine Enterprise Ltd.
18-19/F, Zhongshan Building A
No. 154 Hudong Road
Fuzhou, P.R.C. 350001
Re:Pingtan Marine Enterprise Ltd.
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed March 16, 2020
File No. 001-35152
Dear Mr. Yung:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies, Revenue Recognition, page F-14
1.Please tell us where you provided the quantitative disaggregation of revenue disclosures
based on how economic factors affect the nature, amount, timing and uncertainty of
revenue recognition and cash flows.  Refer to ASC 606-10-50-5 and 50-7.
Note 4. Inventories, page F-19
2.Reference the disclosure that you have $25 million of frozen fish and marine catches work
in progress at December 31, 2019 compared to none in the prior year.  Revise future
filings to briefly describe the nature of "work in progress" and, as applicable, explain the
reasons for material changes in the balance when compared to the prior year in MD&A.
Refer to Instruction 4 of Item 303(a) of Regulation S-K.  Provide us with your proposed

 FirstName LastNameLiMing  Yung
 Comapany NamePingtan Marine Enterprise Ltd.
 April 22, 2020 Page 2
 FirstName LastName
LiMing  Yung
Pingtan Marine Enterprise Ltd.
April 22, 2020
Page 2
revised disclosures.
Note 9. Property, Plant, and Equipment, page F-21
3.We see that you continue to have 37 vessels located in the Arafura Sea in Indonesia that
are not in operation due to the moratorium and that you expect the carrying value of the
fishing vessels to be recoverable based on the undiscounted future cash flows, which
includes the impact of the moratorium.  Given the extended period of the moratorium and
the unknown timing of when fishing will resume in Indonesia, provide us with your
impairment analysis under ASC 360-10-35-17.  In addition, please revise future filings
to include enhanced disclosure about your impairment analysis, estimates made, and
factors that cause the estimate to be sensitive to change.  Refer to ASC 275-10-50-8.
            In closing, 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.
            You may contact Kristin Lochhead, Staff Accountant, at (202) 551-3664 or Kate Tillan,
Senior Accountant, at (202) 551-3604 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Yuri Mikulka