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CONFIDENTIAL TREATMENT REQUEST

REQUESTED BY PINGTAN MARINE ENTERPRISE
LIMITED

PURSUANT TO 17 C.F.R. §200.83

SECTIONS MARKED WITH AN [*] OMIT CONFIDENTIAL
INFORMATION

DELIVERED TO THE U.S. SECURITIES AND
EXCHANGE COMMISSION’S DIVISION OF CORPORATION FINANCE IN AN UNREDACTED COPY OF THIS LETTER

PURSUANT TO 17 C.F.R. §200.83

May 11, 2020

VIA CERTIFIED MAIL AND EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F. Street N.E.

Washington, D.C. 20549

 Re: Pingtan Marine Enterprise Ltd.

Form 10-K for the Fiscal Year
Ended December 31, 2019 (the “Form 10-K”)

Filed March 16, 2020

File No. 001-35152

Dear Mses. Tillan and Lochhead:

This letter (this “Response Letter”)
responds to the comment of the staff (the “Staff”) of the Division of Corporation Finance at the U.S. Securities and
Exchange Commission (the “Commission”), as set forth in the Staff’s letter dated April 22, 2020 (the “Comment
Letter”), to the above referenced filings of Pingtan Marine Enterprise Ltd. (the “Company”). The Company has
filed, via EDGAR, this Response Letter (tagged correspondence).

Pursuant to Rule 83 of the Commission’s
Rules on Information and Requests [17 C.F.R. §200.83] (“Rule 83”) and because of the commercially sensitive nature
of certain information contained herein, the Company is requesting confidential treatment for selected portions of this Response
Letter. The version of this Response Letter filed via EDGAR omits such confidential information. The omitted confidential information
has been replaced in this Response Letter filed via EDGAR with a placeholder identified by a bracketed asterisk [*]. A complete
unredacted version of this Response Letter will be provided to the Staff only in hard copy and not electronically as correspondence
under the Commission’s EDGAR system. The Company has sent to the Staff and the Office of Freedom of Information and Privacy
Act Operations a separate letter (the “Request Letter”) requesting that, pursuant to Rule 83, the omitted confidential
information not be disclosed in response to any request made under the Freedom of Information Act or otherwise.

CONFIDENTIAL TREATMENT REQUESTED BY PINGTAN
MARINE ENTERPRISE LTD.

PURSUANT TO 17 C.F.R. §200.83

U.S. Securities and Exchange Commission

May 11, 2020

Page 2

For your convenience, we have reproduced
in italics below the comment from the Comment Letter with the response following.

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.

RESPONSE:

We advise the Staff respectfully that we
have considered the guidance in ASC 606-10-50-5 and 50-7 in our presentation of the financial statements. We have provided disaggregated
revenue disclosure by species of fish sold in the Management’s Discussion and Analysis of Financial Condition and Results
of Operations (“MD&A”) on page 32 of the Form 10-K. Marine catch is our one and only product line and we have concluded
that the most meaningful disclosure would be by product type pursuant to ASC 606-10-55-91(a) as presented in the Form 10-K.

Beginning with the Form 10-Q for the period
ended March 31, 2020, the Company will include the following disclosure in both the footnotes to the financial statements and the
MD&A, to be updated as applicable for the relevant period:

We catch different species of
fish, ship them back to China and sell the catches to distributors and retailers by acting as a wholesaler. Marine catch is our
one and only product line. The product type, contractual price and quantities are identified in contracts. We do not offer promotional
payments, customer coupons, rebates or other cash redemption offers to our customers, and we do not accept returns from customers.
Our revenues are recorded at a point in time. All of our operations are considered by the Company’s Chief Operating Decision
Maker to be aggregated in one reportable operating segment and our revenue is disaggregated by product type in terms of species
of fish sold pursuant to ASC 606-10-55-91(a).

The revenue is generated from
the sale of frozen fish and other marine catches. We recognize revenue at the amount we expect to be entitled to be paid, determined
when control of the products is transferred to our customers, which occurs upon delivery of and acceptance of the frozen fish by
the customer and we have a right to payment.

We have identified one performance
obligation as the frozen fish and other marine catches identified in the contract are picked up by the customers at our cold storage
warehouse, with revenue being recognized at a point in time. We initially recognize revenue in an amount which is estimated based
on contractual prices. The receivables under contracts, whereby pricing is based on contractual prices, are primarily collected
within180 days.

CONFIDENTIAL TREATMENT REQUESTED BY PINGTAN
MARINE ENTERPRISE LTD.

PURSUANT TO 17 C.F.R. §200.83

U.S. Securities and Exchange Commission

May 11, 2020

Page 3

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 revised disclosures.

RESPONSE:

Frozen fish and marine catches “in
warehouse” represents fish inventory in cold storage warehouses located in China.

Frozen fish and marine catches “work
in progress” represents fish inventory in vessels’ refrigerators, which has not been delivered to ports in China, nor
applied for duty-exemption import into China.

Frozen fish and marine catches “in
transit” represents fish inventory that obtained duty-exemption import permission and is in the process of being shipped
to China.

As of December 31, 2019, 18.7 million kg
of fish were stored in fishing vessels’ refrigerators and recorded as “work in progress” and 91% of which was
delivered to ports in China during the first quarter of 2020. The average unit production cost of this fish was $1.36 per kg. The
average unit sale price was $1.76 per kg in 2019, which is higher than the average unit production cost. As a result, we booked
$25 million of frozen fish and marine catches “work in progress” at December 31, 2019.

The change in the balance of “work
in progress” for the year ended December 31, 2019, as compared to the year ended December 31, 2018, was mainly due to the
increase in the number of vessels in operation in 2019. During the period from 2018 to 2019, we upgraded 59 fishing vessels with
greater tonnage and deployed them to the international waters gradually. All these vessels started fishing operations in 2019 and
brought material change in the balance of frozen fish and marine catches “work in progress” at December 31, 2019 as
compared to the prior-year period.

Beginning with the Form 10-Q for the period
ended March 31, 2020, the Company will include the following disclosure in both the footnotes to the financial statements and the
MD&A, to be updated as applicable for the relevant period:

Frozen fish and marine catches in warehouse represents
fish inventory in cold storage warehouses located in China.

Frozen fish and marine catches work in progress represents
fish inventory in vessels’ refrigerators, which has not been delivered to ports in China, nor applied for duty-exemption
import into China.

CONFIDENTIAL TREATMENT REQUESTED BY PINGTAN
MARINE ENTERPRISE LTD.

PURSUANT TO 17 C.F.R. §200.83

U.S. Securities and Exchange Commission

May 11, 2020

Page 4

Frozen fish and marine catches in transit represents
fish inventory that obtained duty-exemption import permission and is in the process of being shipped to China.

As of March 31, 2020, our total inventory balance was
$50,761,587 compared to $30,527,752 as of December 31, 2019. The change in the balance is mainly attributable to an increase in
frozen fish and marine catches in warehouse by $9.05 million and an increase in frozen fish and marine catches in transit by $15.57
million, a big portion of which was booked as frozen fish and marine catches work in progress as of December 31, 2019.

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.

RESPONSE:

On December 31, 2019, we performed
an impairment test to assess whether these 37 vessels’ carrying value are recoverable.

There are three types of vessels
among these 37 vessels – trawlers, light luring seine vessels and drifters – which can catch various fishes in different
ocean areas. Therefore, these vessels are available for fishing in other fisheries. We are monitoring opportunities to negotiate
with the Indonesian government to resume fishing operations for these vessels. If we are not successful, we will consider deploying
the fishing vessels to operate in other ocean areas that are covered by the Fishery Cooperation Agreements with the Chinese government.

The impairment test was carried
out with reference to the relevant operation data of our comparable vessels, including average fishing quantity, average selling
price, fuel consumption and other costs such as labor cost under normal operation.

Below are the key assumptions applied in the
impairment test:

 a) these fishing vessels will exist over their remaining useful life;

 b) the operation of these fishing vessels will not differ materially from expectation after upgrading
and improvement;

 c) regular maintenance will be carried out annually;

 d) straight-line depreciation is applied;

CONFIDENTIAL TREATMENT REQUESTED BY PINGTAN
MARINE ENTERPRISE LTD.

PURSUANT TO 17 C.F.R. §200.83

U.S. Securities and Exchange Commission

May 11, 2020

Page 5

 e) average fishing quantity of the fishing vessels is under normal operation;

 f) weighted average selling price based on the sales quantity in 2014 as average selling price
of specific fish harvested in Arafura Sea of Indonesia is lower than the selling price in 2019;

 g) fuel cost, labor cost, freight, maintenance, spare parts costs, etc. are under normal operation;
and

 h) reimbursement of certain operating expenses from the Chinese government and tax expenses are
based on the most recent policies issued by the Chinese government.

To calculate the undiscounted
cash inflow, we multiply average fishing quantity by weighted average selling price, and add reimbursement of certain operating
expenses from the Chinese government.

To calculate the undiscounted
cash outflow, we sum up all costs and tax expenses.

To calculate the undiscounted
net cash inflow, we subtract the undiscounted cash outflow from the undiscounted cash inflow.

The following table summarizes
the computation of undiscounted net cash inflow by vessel as of December 31, 2019.

[*]

We have estimated upgrading and
improvement costs based on our historical experience. Our analysis shows that, as of December 31, 2019, the payback period of each
vessel is less than its remaining useful life by at least 4 years and in several cases more than 10 years.

The Company intends to hold these
vessels until the moratorium is removed or vessels have been redeployed. Considering the fact that we are constantly monitoring
the status of the moratorium and are able to redeploy vessels to other fishing territories / locations, we concluded that none
of these vessels was impaired as of December 31, 2019. We will update our impairment analysis on these vessels as long as there
continues to be indicators of impairment.

Beginning with the Form 10-Q
for the period ended March 31, 2020, the Company will include the following disclosure in both the footnotes to the financial statements
and the MD&A, to be updated as applicable for the relevant period:

37 vessels in Indonesian waters are not in operation
because their licenses are currently inactive due to the moratorium. The Indonesian government’s 2014 moratorium on fishing
license renewals has had, and will continue to have, a significant negative impact on our results of operations and financial condition.
Given the impact of the moratorium, the Company assessed the recoverability of these 37 vessels for the year ended December 31,
2019 based on the undiscounted future cash flows and the availability of the vessels for redeployment in other fisheries. The impairment
test was carried out with reference to the relevant operation data of the Company’s comparable vessels and took into account
upgrading and improvement costs based on the Company’s historical experience. As of December 31, 2019, the payback period
of each vessel is less than its remaining useful life and the carrying value of the fishing vessels are expected to be recoverable.
Therefore, no impairment loss was recognized.

CONFIDENTIAL TREATMENT REQUESTED BY PINGTAN
MARINE ENTERPRISE LTD.

PURSUANT TO 17 C.F.R. §200.83

U.S. Securities and Exchange Commission

May 11, 2020

Page 6

Should you or any member of your
team have any further questions or need any additional information, please contact me at +19178595605 or michaelyung@ptmarine.net
if you have any further questions or comments.

    Very truly yours,

    /s/ LiMing Yung

    LiMing Yung

    Chief Financial Officer

 Cc: Yuri Mukalki, Alston & Bird LLP