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November 21, 2023
Mingming Su
Chief Strategy Officer & Director
DouYu International Holdings Ltd
20/F, Building A, New Development International Center
No. 473 Guanshan Avenue
Hongshan District, Wuhan, Hubei Province 430073
People's Republic of China
Re:DouYu International Holdings Ltd
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 001-38967
Dear Mingming Su:
            We have reviewed your November 9, 2023 response to our comment letter and have the
following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our October 12,
2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
General
1.In your response to prior comment 2, you state that “The value indicated for the ‘Amounts
due from the VIEs pursuant to contractual arrangements’ item provided in our September
25, 2023 response represents the amount of fee receivables due to DouYu Yule under the
Business Operation Agreements.” Please explain with greater specificity how this value
was determined, including citations to relevant legal authority under the Investment
Company Act of 1940 (“Investment Company Act”) and, as necessary, the supporting
accounting guidance.

 FirstName LastNameMingming Su
 Comapany NameDouYu International Holdings Ltd
 November 21, 2023 Page 2
 FirstName LastName
Mingming Su
DouYu International Holdings Ltd
November 21, 2023
Page 2
2.We note your response to prior comment 5, including your representation that you
consulted U.S. counsel for U.S. securities law matters. As previously requested, please
confirm whether you have received an opinion issued by counsel regarding your reliance
on the exclusion from the definition of investment company provided by Section 3(b)(1)
under the Investment Company Act.
3.We note your response to prior comment 6. Please advise as to whether you are able to
recalculate your responses to our prior comments in your letters dated November 9, 2023
and September 25, 2023, as of September 30, 2023.
Form 6-K Filed November 21, 2023
Exhibit 99.1, page 1
4.We note the disclosure in your Form 6-K dated November 21, 2023 indicating that Mr.
Chen was arrested “on or about November 16, 2023.” However we also note numerous
articles indicating that Mr. Chen may have been taken into custody much earlier. For
example, CNN reported on November 7, 2023 that Mr. Chen “was being investigated and
had been missing for nearly three weeks.” Please tell us the specific date that Mr. Chen
was arrested. In addition, please confirm that Mr. Chen has been serving as your CEO in
an acting capacity up until his arrest, and whether his arrest impacts his ability to fulfill his
role and responsibilities of CEO for the foreseeable future.
            Please contact Chen Chen at 202-551-7351 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Li He