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CORRESP
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    September 25, 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 August 11, 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.

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

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

 1. We note your response to prior comment 3. Please tell us, and
                                            revise to disclose, the number of mobile annual paying users for each period presented
                                            and tell us your consideration to disclose quarterly average mobile paying ratio information.
                                            In this regard, it is unclear how providing total annual paying user and average mobile
                                            MAU information provides insight into the performance of the mobile aspect of your business,
                                            which you indicate is a focus of management. Also, as previously requested, in your response,
                                            provide us the total average MAUs, total average eSports MAUs and average next
                                            month active user retention rate for PC users for each period presented.

To provide insight into the performance of the mobile aspect of our
business, 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.

Last Paragraph on Page 80:

We derive a substantial portion of our revenues from livestreaming,
mainly from the sale of virtual gifts. In 2020, 2021 and 2022, we generated RMB8,852.2 million, RMB8,596.6 million and RMB6,797.3 million
(US$985.5 million) respectively from livestreaming, representing 92.2%, 93.8% and 95.6% of our total net revenues for the same periods.
In 2022, we had a total of 15.5 million annual paying users, and 12.7 million annual
mobile paying users.

In response to the Staff’s comment, the Company undertakes to
add the above-mentioned disclosure of mobile annual paying users in its future filings, which allows the investors to derive the annual
average mobile paying ratio based on the total average mobile MAUs that were disclosed in the 2022 Annual Report, and serves to provide
insight into the total annual livestreaming revenue generated across both PC and mobile platforms. In addition, the Company also respectfully
provides the Staff the following information as requested:

    2020
    2021
    2022

    Total average MAUs (in million; fourth quarter of each year, including both PC and mobile users)
      173.0
      169.0
      94.1

    Mobile average MAUs (in million; fourth quarter of each year, already disclosed in the 2022 Annual Report)
      58.2
      62.4
      57.4

    PC average MAUs (in million; fourth quarter of each year)
      114.8
      106.6
      36.7

    Total average eSports MAUs (in million; fourth quarter of each year, including both PC and mobile users)
      108.2
      92.4
      55.3

    Average next month active user retention rate for PC users
      23%
      19%
      28%

The total
average MAUs and total average eSports MAUs both declined from 2020 to 2022, which was mainly attributable to the decline in PC MAUs.
As previously discussed in the response letter dated July 28, 2023, in light of the evolving user behavior observed on game-centric
livestreaming platforms with a greater emphasis on mobile devices over PCs, which was evidenced by the significantly lower user retention
rate for PC users in comparison to mobile users, the management is focusing more on mobile apps and the performance of mobile users from
an operational standpoint to maintain and acquire users with higher stickiness and willingness to pay. From 2020 to 2022, the user retention
rate for mobile users was around 60%-70%, whereas that for PC users was around 20% to 30%. Therefore, the Company has elected
to disclose average mobile MAUs instead of average PC MAUs or total average MAUs in the 2022 Annual Report, as the average mobile
MAUs serves better to reflect the Company’s evolving operational focus on mobile users.

2. You also state in your response to comment 3 that 25% of livestreaming virtual gifts were
                                        purchased via PCs in 2022. Please clarify whether this means that PC virtual gift sales comprised
                                        25% of total livestreaming revenue or tell us the percentage of livestreaming revenue generated
                                        from PC users. Also, while you state that management is shifting their focus to mobile apps and
                                        mobile users, considering registered PC users represented 29% of total new registered users in
                                        fiscal 2022 and 25% of virtual gift were purchased via PCs, explain further why you believe that
                                        information regarding this user base is not material to an understanding of your business.

In response to the Staff’s comment, the Company respectfully
clarifies that PC users contributed to approximately 25% of livestreaming revenue generated through the sales of virtual gifts in 2022.
The Company further notes that given that its user base only consists of two user groups (i.e. PC users and mobile users), the assessment
of materiality concerning one user group should be conducted on a comparative basis. In view of the evolving user behavior trends towards
mobile platforms shown in the table supplemented in response to comment 1 above, coupled with the contribution of mobile users to certain
operating metrics, such as new registered users and the number of virtual gift purchases, surpassed that of PC users by an approximately
three-fold margin. Therefore, the Company respectfully advises the Staff that it believes the details regarding PC user base is not material
to an understanding of its business.

Nonetheless, in response to the SEC’s comment 1 above, the Company
undertakes to add the disclosure of mobile annual paying users in its future filings, which allows the investors to derive the number
of annual PC paying users. This operating metric, together with the users related operating metrics that were disclosed in the 2022 Annual
Report (i.e. total annual paying users, total average mobile MAUs, average eSports mobile MAUs and average next month active user retention
rate for mobile users), will enable the investors to make an informed decision based on their understanding of the Company’s user
base and user engagement.

General

 3. We note your revised disclosures in response to prior comment
                                            11. Please ensure that your disclosures elsewhere do not narrow risks related to operating
                                            in the PRC to mainland China only. Where appropriate, describe PRC law and then explain how
                                            the law in Hong Kong and Macau differs from PRC law and describe any risks and consequences
                                            to the company associated with those laws.

The Company respectfully advises the Staff that its disclosures elsewhere
in the annual report (i.e. apart from the context that describes PRC rules, laws, regulations, regulatory authority, and any PRC entities
or citizens under such rules, laws and regulations and other legal or tax matters) do not narrow risks related to operating in the PRC
to mainland China only. However, the Company believes it is only necessary to disclose material risks related to its operations. The
Company further respectfully advises the Staff that it currently does not have operations in Hong Kong or Macau, and as a result, the
Company believes that it is not subject to material operational risks associated with operating in Hong Kong or Macau. The Company undertakes
to provide the requested disclosure in its future filings when it has material operations in Hong Kong or Macau.

4. We note that in your responses to prior comments 12 and 13, you only provide legal analysis
                                        regarding “significant subsidiaries.” However, the previous comments asked for such
                                        analysis as to all subsidiaries, whether or not “significant.” Accordingly, please
                                        clarify how you define “significant subsidiaries” in this context. Also provide the
                                        same legal analysis for each subsidiary, including Wuhan Ouyue, Wuhan Douyu and subsidiaries
                                        you do not categorize as significant. Further, please address the following:

The Company
respectfully submits that the significant subsidiaries of the Company discussed in our response to prior comments 12 and 13 include all
of the Company’s subsidiaries set forth in Exhibit 8.1 of its 2022 Annual Report in accordance with the form requirements
of Form 20-F. Form 20-F requires a registrant to provide a full list of its subsidiaries in Exhibit 8.1, omitting only
the names of subsidiaries that, in the aggregate, would not be a “significant subsidiary” as defined in rule 1-02(w) of
Regulation S-X as of the end of the year covered by the report. In other words, the significant subsidiaries and VIEs (as defined below)
set forth in Exhibit 8.1 of the Company’s 2022 Annual Report contributed to over 90% of the total consolidated assets of the
Company as of December 31, 2022. The Company believes that such significant subsidiaries are central to an analysis of the Company
under the Investment Company Act because ownership interests in and advances to such significant subsidiaries together represent approximately
80% of the Company’s total unconsolidated assets (exclusive of U.S. government securities and cash items) as of June 30, 2023.
On the other hand, ownership interests in and advances to the subsidiaries that are not significant subsidiaries, and not discussed in
our prior response (the “Immaterial Subsidiaries”), together represent less than 20% of the Company’s total
unconsolidated assets (exclusive of U.S. government securities and cash items) as of June 30, 2023. None of the Immaterial Subsidiaries
(other than DouYu Investment Limited, as discussed in footnote 3 below) holds material amounts of securities, and none of the Immaterial
Subsidiaries have conducted securities offerings or borrowing transactions in the U.S. Nonetheless, even if the Immaterial Subsidiaries
were deemed to be investment companies under the Investment Company Act, and interests in such Immaterial Subsidiaries were counted as
investment securities, because such interests are so small in value relative to the Company’s other assets that are not investment
securities, the Company would still satisfy the assets test under Section 3(a)(1)(C).1 Thus, the Company respectfully
submits that an analysis of each Immaterial Subsidiary under the Investment Company Act is not relevant for the Section 3(a)(1) analysis
of the Company, and in the updated analysis as of June 30, 2023 provided below, the Company has conservatively treated interests
in the Immaterial Subsidiaries as investment securities (even though such Immaterial Subsidiaries may either not be investment companies
or qualify for an exemption under the Investment Company Act other than Section 3(c)(1) or 3(c)(7)). The updated analysis below
therefore includes a discussion of the Company and its significant subsidiaries and, to the extent relevant for the Rule 3a-1 analysis
of Wuhan DouYu Culture Network Technology Co. Ltd. (“DouYu Yule”), an analysis of Wuhan Ouyue Online TV Co.
Ltd. (“Wuhan Ouyue”) and Wuhan Douyu Internet Technology Co., Ltd. (“Wuhan Douyu” and, together
with Wuhan Ouyue, the “VIEs”), but does not include a separate discussion of each Immaterial Subsidiary.

●
Clarify whether you own strategic investments through subsidiaries other than DouYu Investment Limited.

As of June 30,
2023, the Company owns strategic investments through DouYu Investment Limited, DouYu Yule and Wuhan DouYu. The treatment of such
strategic investments for purposes of the analysis of the Company under Section 3(a)(1)(C) is discussed in greater detail below.

1      The
Company notes that an analysis of three of the Immaterial Subsidiaries (Betta Fish Inc., Betta Fish Hong Kong Limited and DouYu Japan
Inc.) is relevant for the analysis (i.e., under the assumption that short-term bank time deposits are not treated as cash items) in our
response to comment 5 below. Our response to comment 5 below therefore includes an analysis of those three Immaterial Subsidiaries under
Section 3(a)(1)(C).

●
Update all figures and calculations in your responses to conform to your financial statements as of June 30, 2023.

Updated
analysis under Section 3(a)(1)(A):

The Company respectfully submits the updated analysis below with respect
to the factors outlined in Tonopah Mining Co. (26 S.E.C. 426 (1947)), which demonstrates that the Company and its subsidiaries
and the VIEs (collectively, “DouYu”) are primarily engaged in the business of developing and operating online interactive
gaming and entertainment livestreaming platforms, and are not and do not hold themselves out as being engaged primarily, and do not propose
to engage primarily, in the business of investing, reinvesting or trading in securities. Under Tonopah Mining, being “primarily
engaged” in a business or businesses other than that of investing, reinvesting, owning, holding or trading in securities was interpreted
under the Investment Company Act to depend on a facts and circumstances review, including the following principal factors: (1) an
issuer’s historical development, (2) its public representations of policy, (3) the activities of its officers and directors
and, most importantly, (4) the nature of its present assets and (5) the sources of its present income. Any one factor is not
determinative, and as interpreted by the courts, the overarching objective of the Tonopah Mining analysis is to determine whether
reasonable investors would view an issuer “as an operating company rather than a competitor with a closed-end mutual fund.”2
Applying such factors to DouYu, it is clear that DouYu is primarily engaged in the online interactive gaming and entertainment
livestreaming business, and not in the business of investing, reinvesting or trading in securities:

A. The Company

1)            DouYu
is primarily