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CORRESP
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Golden Bull Limited

707 Zhang Yang Road, Sino Life Tower,
F35

Pudong, Shanghai, China 200120

August 30, 2019

Via Edgar

Mr. John Spitz

Division of Corporation Finance

Office of Financial Services

U.S. Securities and Exchange Commission

    Re:
    Golden Bull Limited

    Form 20-F for Fiscal Year Ended December 31, 2018

    Filed on April 30, 2019

    File No. 001-38421

Dear Mr. Spitz:

This letter is in response
to the letter dated July 17, 2019, from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) addressed to Golden Bull Limited (the “Company”, “we”, and “our”)
regarding the Annual Report on Form 20-F (“Form 20-F”) previously filed on April 30, 2019. For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly.

Item 15. Controls and Procedures, page
105

1. We note your proposed revised disclosure
in response to comment 4. Please ensure that your revised disclosure clearly identifies which of the listed items represented a
material weakness that resulted in your determination that you did not maintain effective internal control over financial reporting
as of December 31, 2018. Refer to Item 15(b)(3) of Form 20-F. Please also ensure the disclosure in your next Form 20-F clearly
describes the changes in internal control over financial reporting that occurred during the year as part of your remediation activities
and to clearly describe any remaining actions planned to remediate the identified material weaknesses.

Response: In response to the Staff’s
comment, we have revised our disclosures accordingly below and will also do so in our future filings:

 Item 15 (b) Management’s Report on Internal Control Over Financial Reporting

Our management is responsible
for establishing and maintaining adequate internal control over financial reporting, as such term is defined in Exchange Act Rule
13a-15(f). Our internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability
of financial reporting and the preparation of financial statements for external purposes in accordance with international financial
reporting standards (“IFRSs”). Because of its inherent limitations, internal control over financial reporting may not
prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk
that controls may become inadequate because of changes in conditions or because the degree of compliance with policies or procedures
may deteriorate. Under the supervision and with the participation of our management, including our chief executive officer and
chief financial officer, we conducted an assessment of the effectiveness of our internal control over financial reporting as of
December 31, 2018. The assessment was based on criteria established in the framework Internal Control—Integrated Framework
(2013), issued by the Committee of Sponsoring Organizations of the Treadway Commission. Based on this assessment, management determined
that, as of December 31, 2018, we did not maintain effective internal control over financial reporting due to the existence of
the following material weaknesses:

 o Lack of sufficient full-time personnel with appropriate levels of accounting knowledge and experience
to monitor the daily recording of transactions, address complex U.S. GAAP accounting issues, and prepare and review financial statements
and related disclosures under U.S. GAAP, and as a result, the Company may not be able to identify and monitor significant accounting
issues appropriately on a timely basis;

 o Lack of a functional internal audit department or personnel that monitors the consistencies of
the preventive internal control procedures, and as a result, the Company may not be able to discover the existence of problems
and prevent the problematic behavior in internal control;

 o Lack of adequate policies and procedures in internal audit function to ensure that the Company’s
policies and procedures have been carried out as planned; and

 o Lack of well-structured IT general control policies and procedures for documentation of program
changes, periodic transaction log reviews, control quality evaluations, backup restoration tests and centralized anti-virus detections,
which may result in failure to accurately collect operational data to prepare the financial statements.

 o Lack of proper segregation of duties within accounting functions.

 o Significant deficiencies were also detected at Dianniu, one of our VIEs, which in the aggregate,
constitute a material weakness and create a reasonable likelihood that a material misstatement of our annual and interim financial
statements will not be prevented or detected on a timely basis. Such deficiencies include: (i) lack of reviewed documentation for
management’s approval on aging analysis and as a result, the Company may not be able to accrue provision for bad debt appropriately
on a timely basis; and (ii) lack of sufficient monitoring of the employee resignation procedure, which may result in an inaccurate
number of employees in the annual report.

As a company with limited
resources, the Company does not have the resources to fund sufficient staff to ensure a complete segregation of responsibilities
within the accounting function. However, management has carried out and is planning to undertake the following actions to remediate
the material weakness described above:

 (1) Recruiting qualified consultants with appropriate levels of knowledge and experience in U.S. GAAP
reporting to assist in resolving accounting issues in non-routine or complex transactions;

 (2) Setting up an Internal Audit Department and establishing formal internal control policies and procedures,
implementing an ongoing initiative and training to relevant personnel,

 (3) Providing continuous U.S. GAAP trainings to relevant employees;

 (4) Making quarterly aging analyses, which will be reviewed and confirmed by the CFO;

 (5) Further standardizing the employees’ resignation process; the resignation report of employees
above the manager level (including managers) shall be approved by the CEO with approval records and signature;

 (6) Setting up IT strategic plans, annual plans and budgeting for it to be consistent with business
development, maintaining IT meeting minutes and communicating through emails with relevant departments, setting up IT Best Practice
Standards and evaluating the IT department performance annually, maintaining records for IT change authorizations, terminating
user access rights the same day for any employees that leave the Company, standardizing and managing the anti-virus software with
specific designated personnel, periodically reviewing the logs to identify any unusual transactions, performing restoration tests
for backups regularly, evaluating third-party services annually, and terminating the ones with bad performance;

    2

Note 7 - Taxes, page F-19

2. We note your response to comment
6. Please address the following:

 ●  References to “taxable income”
in your response appear to represent “Total operating revenues, net” as presented in your statement of operations on
page F-4. Please revise your analysis to instead provide us historical and forecasted PRC taxable operating income/(loss) with
appropriate detail of the significant revenue and expense line items. Please provide us your historical results by quarter if available.

 ●  Please provide us your historical and
forecasted US GAAP operating income/(loss) before taxes or taxable operating income/(loss) by country (i.e. PRC, Cayman Islands,
etc.) and explain how historical income was generated for each country and ensure any differences in forecasted income/(loss) between
countries is explained.

 ●  In your accounting analysis you have
forecasted revenue (21%) and expense (13%) growth based only on increases experienced from fiscal 2017 to fiscal 2018. Please tell
us how you considered in your analysis the potential for ongoing PRC regulatory reform and planned changes to your business model
(i.e. entrance into car leasing business, production and sales for Internet of Things technology and technical consulting) in support
of these revenue and expense growth rates.

 ●  You have also forecasted in your accounting
analysis business consulting expenses and professional fees to decrease by 50% when compared to fiscal 2018 since you considered
these expenses were mainly in relation to one-time IPO listing expenses. However, we note disclosure on pages 73-74 that business
consulting expenses were due to the engagement of professional teams to monitor and provide business advice on your business in
the area of human resource strategic management and business strategic management. Please update your analysis, based upon your
changing business model, to explain in further detail how you have determined these significant expenses will reduce by 50% in
future periods.

Response: In response to the Staff’s
comment, we have revised our analysis accordingly as below:

 ●  Please refer to “Taxable Income
and Reconciling Items” attached hereto as Exhibit A which provides our historical and forecasted PRC taxable operating
income/(loss) with appropriate details regarding significant revenue and expense line items.

 ●  Please refer to “Operating and Forecasted
Income by Country” attached hereto as Exhibit B which provides our historical and forecasted US GAAP operating income/(loss)
before taxes or taxable operating income/(loss) by country.

 ●  In our forecast, we used the growth rate
of 21% in revenue because the Company’s revenue level has been gradually increasing since the fourth quarter of 2018. In
the first quarter of 2019, the operating result was made available at the end of April 2019, right before the 2018 20-F was filed,
and the Company’s revenue increased 101% over the fourth quarter of 2018. Therefore, the Company used the growth rate of 21% in
revenue based on the fluctuation of loan volumes processed from fiscal year 2017 to fiscal year 2018, which appears to be achievable
and conservative for the Company according to the positive performance in the first quarter of 2019.

 ●  We have forecasted business consulting
expenses and professional fees to decrease by 50% when compared to fiscal 2018, because these expenses were mainly attributable
to consulting services in the area of human resource strategic management and business strategic management related to IPO. The
original projection and accounting analysis we provided was largely based on the March 31, 2019 quarterly performance which was
made available at the end of April 2019 right before the 2018 20-F was filed. However, the overall performance of the P2P industry
has declined in the second quarter of 2019 due to the increasingly stricter regulations of the P2P industry by the Chinese government.
As a P2P operator, we have also been affected, resulting in a sharp decline in the Company’s operations in the second quarter
of 2019. Please refer to “New Forecast” attached hereto as Exhibit C which provides our revised forecast and
accounting analysis.

    3

3. For each reconciling item in your
effective tax rate reconciliation for 2017 and 2018 on page F-19, please clearly tell us and revise your future filings, to the
extent material, to explain:

 ●  the nature of the reconciling item,
and

 ●  if the item represents income or expense
and how the item is treated differently for taxes.

Also, clearly explain to
us why Cayman non-deductible expenses decrease your effective tax rate.

Response: In response to the Staff’s
comment, please refer to our explanation in Exhibit A attached hereto and we will also revise our future filings accordingly

4. We note that 47% of your losses before
taxes in 2018 is presented as foreign (i.e. non-PRC) on page F-19. Please tell us and revise future filings to clearly describe
how income is generated in each geographic market as required by Item 4 and Item 5 of Form 20-F.

Response: In response to the Staff’s
comment, we have revised our disclosures accordingly below and will also do so in our future filings:

 ●  All of our income from inception to 2018
is generated in China. We facilitate loans by connecting borrowers and lenders, preparing all necessary paperwork related to borrowers’
applications and assisting with securing collateral. Our primary sources of revenue consist of fees received for transactions through
our platform and include transaction and management fees, which are described in further detail below:

 o Transaction Fees: Transaction fees are paid by borrowers to the Company for the work the Company
performs through its platform. These fees are recognized as a component of operating revenue at the time of loan issuance. The
amount of these fees is based upon the loan amount and other terms of the loan, including credit grade, maturity and other factors.
These fees are non-refundable upon the issuance of loan.

 o Management Fees: Loan borrowers pay a management fee on each loan payment to compensate us for
services provided in connection with facilitation of the loan transactions, including review of a borrower’s application
with required supporting documentation, evaluation of such borrower’s credit, assessing and verification of collaterals as
well as the maintenance of profiles in our system. The Company records management fees as a component of operating revenue at the
time of loan issuance. The amount of these fees is based upon the loan amount and other terms of the loan, including credit grade,
maturity and other factors. These fees are non-refundable upon the issuance of loan.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Joan Wu, Esq.,
of Hunter Taubman Fischer & Li LLC, at (212) 530-2208.

Very truly yours,

    /s/ Erxin Zeng

    Name:
    Erxin Zeng

    Title:
    Chief Executive Officer and Chairman of the Board of
Directors

CC: Joan Wu, Esq. Hunter Taubman Fischer & Li LLC

Eddie Wong, Friedman LLP

    4

Exhibit A

    For the years ended Dec 31,

    2018-

dianniu per book
    2017-

dianniu per book
    2016-

dianniu per book

    Note

    OPERATING REVENUES

    Transaction Fees
    $ 3,994,195
    $ 3,307,984
    $ 1,561,172

    Management Fees
      4,399,578
      4,037,700
      2,264,241

    Sales taxes
      (504,572 )
      (391,927 )
      (119,643 )

    Total operating revenues, net
      7,889,201
      6,953,757
      3,705,770

    OPERATING EXPENSES

    Selling
      (4,940,784 )
      (3,910,646 )
      (1,434,662 )

    General and administrative
      (4,850,104 )
      (3,647,862 )
      (1,623,837 )

    Research and development
      (447,884 )
      (485,852 )
      (417,901 )

    Total operating expenses
      (10,238,772 )
      (8,044,360 )
      (3,476,400 )

    LOSS FROM OPERATIONS
      (2,349,571 )
      (1,090,603 )
      229,370

    Adjustment item from Loss from operations to Taxable income/loss:

    Non-deductable expense
      183,215

    Note 1

    Non-taxbale income
      (49,699 )

    Note 2

    Temporary difference
      33,764
      (37,729 )
      (9,620 )

    Note 3

    Taxable income/loss
      (2,182,292 )
      (1,128,332 )
      219,750

 Note  There is no corporate income tax in Cayman and expenses
occurred in Cayman are non-deductible in China. As a result, expenses occurred in Cayman are permanent tax differences and is
not included in this sheet.

There is no revenue but only expenses
occurred in another three subsidiares in China,Baoxun,Youwang and Fuyu. As a result, the Company forcast there won’t be profit
in the future in these three subsidiares,so expenses occurred in  these three subsidiares is not included in this sheet.

 Note 1 Business entertainment that exceed 5‰ of annua