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CORRESP
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    July 28, 2023

    Re:

    DouYu International Holdings Ltd

    Annual Report on Form 20-F

    Filed April 25, 2023

    File No. 001-38967

Austin Pattan

Jennifer Gowetski

Chen Chen

Kathleen Collins

Office of Technology

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Dear Austin Pattan, Jennifer Gowetski, Chen Chen, and Kathleen Collins:

This letter sets forth the responses of DouYu International Holdings
Ltd (“DouYu” or the “Company”) to the comments (the “Comments”) the Company received
from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in a letter
dated June 16, 2023.

For your convenience, we have included herein the comment in bold,
and the Company’s responses are set forth immediately below the Comment.

*	     *	     *	     *

General Note to the Staff:

The Company respectfully submits in this letter its proposed updates
to the disclosures contained in the annual report for the year ended December 31, 2022 (the “2022 Annual Report”),
which, subject to the Staff’s review and further updates and adjustments to be made in connection with any material development
of the subject matters being disclosed, will be included in the Company’s annual report for the year ending December 31, 2023
(the “2023 Annual Report”) and future filings, to the extent applicable.

    1

Annual Report on Form 20-F for the fiscal year ended December 31,
2022

Item 3. Key Information, page 1

 1. Please revise to include the diagram of your corporate organizational structure in the forepart of the filing.

In responses to the Staff’s comment, the Company respectfully
advise the Staff that it intends to insert the referenced disclosure as follows in its 2023 Annual Report and future filings. Page reference
is made to the 2022 Annual Report to illustrate the approximate location of the disclosure.

Page 3 (immediately before the caption “Contractual
Arrangements with the VIEs and the VIEs’ Respective Shareholders”):

Corporate
Structure

The following
diagram illustrates our corporate structure as of the date of this annual report, including our significant subsidiaries and VIEs.

 Notes:

 (1) The sole shareholder of Wuhan Ouyue is Mr. Shaojie Chen, our founder, CEO and
director.

 (2) The shareholders of Wuhan Douyu and their relationship with our company are as follows:
(i) Mr. Chen (50.23%), our founder, CEO and director; (ii) Linzhi Lichuang (18.98%), an affiliate of Nectarine, one of
our shareholders; (iii) Beijing Fengye (13.16%), with 99.99% of its interests owned by Wuhan Ouyue; (iv) Beijing Phoenix (8.08%),
an affiliate of Phoenix Fuju Limited, one of our shareholders; (v) Mr. Wenming Zhang (3.92%), our co-founder, former co-CEO
and former director, and (vi) Wuhan Chaosai Business Information Consulting Partnership (Limited Partnership) (5.63%), with 99.99%
of its interests owned by Wuhan Ouyue.

    2

Condensed Consolidating Schedule, page 9

 2. Please revise your Condensed Consolidating Schedule as follows:

 · Include
                                            a column for the WFOE separate from the other subsidiaries and present these columns in between
                                            the "Our Company" and "VIE and VIEs' subsidiaries" columns.

 · Disclose "Investment in subsidiaries" and "Amounts due
from VIEs" in two separate line items. To the extent the "Investment in subsidiaries" includes amounts related to both
equity method investments and "investments" through contractual arrangements, revise to present such amounts in separate line
items to avoid any implication that the VIE arrangements are similar to an equity method investment.

 · Present amounts due to/due from between the VIEs and the parent company
and the VIEs and the WFOE separately from any amounts due to/due from between the parent and or subsidiaries and their equity owned subsidiaries.

 · Present any revenue and costs and expenses related to service fees paid
by the VIEs to the WFOE and/or parent company separately from the other costs and expenses of the VIEs.

 · To the extent the line item "Loss from equity in subsidiaries and
the VIEs and VIEs' subsidiaries" includes earnings/losses from equity method investments as well as amounts from interests in the
VIEs through contractual arrangements, revise to present such amounts in separate line items as the current presentation implies the VIE
arrangements are similar to an equity method investment.

 · Revise the cash flow information as necessary based on revisions requested
in above bullet points.

In response to the Staff’s Comments, the Company intends to replace
the content in the “Item 3. Key Information—Condensed Consolidating Schedule” with the referenced disclosure (as set
forth in the Appendix I to this response letter) in the 2023 Annual Report and future filings, subject to appropriate updates
for future financial periods.

Specifically, the Company proposed to revise that (1) the column
of “WFOE” has been separated from the column of "Other Subsidiaries", and has been presented between the "Our
Company" and "VIE and VIEs' subsidiaries" columns in each schedule, (2) "Investment in subsidiaries" and
 "Deficit in VIEs and VIEs’ subsidiaries" have been presented in two separate rows, in which "Deficit in VIEs"
represents the amounts of accumulated losses from VIEs that exceeding the investment’s carrying amounts, (3) amounts due to/from
between the VIEs and other subsidiaries and amounts due to/from between the VIEs and the WFOE have been presented separately as suggested
in the Condensed Consolidating Balance Sheets, and there were no such balance between the parent company and the VIEs during the reporting
periods, (4) revenue and costs and expenses between the WFOE and the VIEs in accordance with the contractual arrangements have been
separately presented in the Condensed Consolidating Statements of Operations Data, (5) the line item "Loss from equity in subsidiaries
and the VIEs and VIEs' subsidiaries" has been separated into two line items as "(Loss) Income from equity in subsidiaries"
and "Share of income(loss) from VIEs", and (6) the cash flow information has been updated accordingly.

    3

Item 5. Operating and Financial Review and Prospectus, page 123

 3. We note that your definition of MAUs only refers to the number of active mobile users in a given month. Considering your platform
is operated on both mobile apps and PCs, please tell us what measure you use to monitor non-mobile users and revise to include a quantified
discussion of such measures. In this regard, we note your definition of MAUs included in the December 31, 2021 Form 20-F included
both the number of active PC users and mobile users, and your definition of active users on page ii of this filing refers to both
PC and mobile users. In addition, you state on page 56 that for performance tracking purposes you monitor metrics such as active
users, which appears to refer to all active users and not just mobile users. Similarly, we note your average eSports MAU and average next
month active user retention rate have also been revised to only refer to mobile users. Tell us how you monitor such measures for non-mobile
users and revise to include a quantified discussion of such measures. In your response please provide us your total MAUs, average eSports
MAUs and average next month active user retention rate for both PC and mobile users for each period presented. Refer to SEC Release 33-10751.

In response to the Staff’s comment, the Company respectfully
advises the Staff that in light of the evolving user behavior observed on game-centric livestreaming platforms with a greater emphasis
on mobile devices over PCs, the management is focusing more on mobile apps and the performance of mobile users from an operational standpoint.
Such observation is also supported by the operating metrics related to new user registration and user consumption behavior. In 2021 and
2022, the number of platform’s new registered users were 39.1 million and 38.4 million, respectively. Among these new registered
users, the percentage of PC registration decreased from 42% in 2021 to only 29% in 2022. In terms of user consumption behavior, only 27%
and 25% of livestreaming virtual gifts were purchased via PCs in 2021 and 2022, respectively. Due to the management’s shifting focus
from an operational standpoint, the PC MAUs generally decreased from 2020 to 2022. This decline can be attributed to management’s
reduced emphasis on maintaining and engaging PC users during this period. As a result of the above, the Company believes that the current
disclosure is more appropriate in light of user behavior and revenue contribution, which reflects its latest operating strategies and
provides investors with sufficient information to assess the magnitude and engagement of its users.

Nonetheless, to provide the investors with more clarity, the Company
intends to revise the referenced disclosure as follows in its 2023 Annual Report and future filings. Page reference is made to the
2022 Annual Report to illustrate the approximate location of the disclosure.

Second to Last Paragraph on Page 56:

For performance tracking purposes, we monitor metrics such
as the number of registered user accounts, active mobile users
and paying users. We calculate certain operating metrics in the following ways: (a) the number of registered users, which refers
to the number of users that has registered and logged onto our platform at least once since registration; (b) the number of active
mobile users, which refers to the number of users who visited our platform
through PC or mobile app at least once in a given period; and (c) the number of paying users, which refers
to the number of users that have purchased virtual gifts on our platform at least once in a given period. The actual number of individual
users, however, is likely to be potentially significantly lower than that of registered users, active mobile
users and paying users due to various reasons such as fraudulent representation or improper registration. Some of our user
accounts may also be created for specific purposes such as to increase virtual gifting for certain performers in various contests, but
the number of registered users, active mobile users and paying users do
not exclude user accounts created for such purposes. Furthermore, we historically focused
on the number of active users, which encompasses the number of users who visited our platform through either PC or mobile app at least
once in a given period. As a result of the evolving user behaviors observed on game-centric livestreaming platforms with a greater emphasis
on mobile devices over PCs, our management is focusing more on mobile apps and mobile users from an operational perspective, and uses
the number of active mobile users to track the scale and engagement of our users. Due to our shifting focus from an operational standpoint,
the PC MAUs generally decreased from 2020 to 2022. We have limited ability to validate or confirm the accuracy of information
provided during the user registration process to ascertain whether a new user account created was actually created by an existing user
who is registering duplicative accounts. The respective number of our registered users, active mobile
users and paying users may overstate the number of individuals who register on our platforms, sign onto our platforms,
purchase virtual gifts or other products and services on our platforms and access DouYu.com, respectively, which may lead to an inaccurate
interpretation of our operating metrics.

    4

Insert the following as the second paragraph on page 124:

Furthermore,
we historically focused on the number of active users, which encompasses the number of users who visited our platform through either PC
or mobile app at least once in a given period. As a result of the evolving user behaviors observed on game-centric livestreaming platforms
with a greater emphasis on mobile devices over PCs, our management is focusing more on mobile apps and mobile users from an operational
perspective, and uses the number of active mobile users to track the scale and engagement of our users. Due to our shifting focus from
an operational standpoint, the PC MAUs generally decreased from 2020 to 2022.

 4. You state that your ability to attract and retain popular streamers is a factor affecting your results of operations. Please tell
us what measures you use to monitor your streamer base and evaluate the popularity or influence of streamers, and revise to include a
quantified discussion of such measures. In this regard, we note that you refer to top streamers throughout this filing and use the terms
 "top-tier" and "mid-tier" to describe your streamers during your earnings calls. In your response, provide us with
the number of total streamers, top-tier streamers and mid-tier streamers for each period presented.

In response to the Staff’s comment, the Company
respectfully advises that for the streamers who possess large fan bases, generate significant user traffic, exhibit exceptional
revenue-generating capabilities or are otherwise deemed valuable in their streaming genres or sections, the Company typically enter
into exclusive contracts with them (the “Exclusive Streamers”). The Exclusive Streamers consist of all of the
 “top/top-tier” and “mid-tier” streamers, and the Company's core operational efforts are typically focused on
the Exclusive Streamers. As of December 31, 2022, the Company had over 28,000 Exclusive Streamers, growing significantly from
over 18,000 as of December 31, 2020. Our Exclusive Streamers in aggregate contributed to 74.9%, 73.1% and 82.4% of total
viewing hours on its platform for the years ended December 31, 2020, 2021 and 2022, respectively. In terms of revenue
contribution, our Exclusive Streamers in aggregate contributed 72.4%, 67.5% and 61.0% of the living streaming revenue for the years
ended December 31, 2020, 2021 and 2022, respectively, which was partially due to our operational efforts in streamer
diversification.

To provide the investors with additional quantitative information on
the popularity and influence of the Company’s popular streamers, the Company undertakes to include (a) the number of the Exclusive
Streamers and (b) the revenue contribution of such streamers in its 2023 Annual Report and future filings (with reference disclosure
revision as set forth below).

    5

The Company also respectfully clarifies that the classification of
 “top/top-tier" and "mid-tier" streamers are dynamic and relatively subjective, as they vary across different streaming
genres or sections. The management takes a holistic approach in selecting, evaluating and managing its streamers based on a myriad of
factors, such as their fan base, activity levels, live-streaming hours and revenue generation capabilities, as well as user traffic, user
viewing hours and user bullet chats. In line with the attributes of different streaming genres or sections, the management dynamically
adjusts the weight given to each of these factors when evaluating the streamer performance within a particular genre or section. For example,
for a newly launched content section, the management focuses more on user traffic and activity levels of both streamers and their users,
whereas for a relatively mature content section with large user traffic and interaction, the management tends to focus more on user viewing
hours and streamers’ revenue generation capabilities. As such, a streamer with a fan base of 50,000 might be considered a top-tier
streamer within a newly-launched, niche content genre, but could be regarded as a mid-tier streamer within a more popular content section,
such as League of Legends. As a result, it is challenging for the Company to pinpoint or provide a specific quantity of top-tier or mid-t