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CORRESP
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January 12, 2024

    Re:

    DouYu International Holdings Ltd

    Annual Report on Form 20-F

    Filed April 25, 2023

    File No. 001-38967

Ms. Chen Chen

Ms. Kathleen
Collins

Office of Technology

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Dear Ms. Chen
and Ms. 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 November 21, 2023.

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

*	     *	     *	     *

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.

In
the breakdown of DouYu Yule’s assets as of June 30, 2023 provided in our response letter dated September 25,
2023 (the “September Response”), and as updated below, the value indicated for “Amounts due from the
VIEs pursuant to contractual arrangements” represents the remaining amount of fee receivables due to DouYu Yule and unpaid as
of the relevant date under its exclusive business operation and cooperation agreements (the “Business Operation
Agreements”) with Wuhan Ouyue Online TV Co. Ltd. (“Wuhan Ouyue”) and Wuhan Douyu Internet Technology
Co., Ltd. (“Wuhan Douyu” and, together with Wuhan Ouyue, the “VIEs”). As described in our
response letter dated November 9, 2023 (the “November Response”), DouYu Yule provides business support,
technical and consulting services to the VIEs.1 Pursuant
to the Business Operation Agreements, each VIE pays a monthly fee for such services, which is determined based on industry and
market factors and is subject to adjustment by DouYu Yule in its sole discretion. For example, in determining the pricing of the
service fee payable to DouYu Yule, the Company uses a third-party database that calculates the cost markup rate of independent third
parties providing similar services in similar industries in the market.

 1
For example, DouYu Yule provides services to support the research and development of the core technologies supporting the
platforms operated by the VIEs, such as accurate content recommendations, front-end development and design, bandwidth optimization and
high-quality audio and video effect presentations.

Rule 3a-1
specifies that the value of assets to be used in applying the 45% assets test thereunder is the “value” of such assets
as defined in Section 2(a)(41) of the Investment Company Act which, for assets owned at the end of the last preceding fiscal
quarter, means “fair value” at the end of such quarter.2 The Commission has stated that there is no
single standard for determining the “fair value” of an asset (i.e., the price that would be received to sell such asset
in an orderly transaction between market participants at the measurement date), which depends on the individual circumstances of
each case.3 In the case of DouYu Yule’s receivables
from the VIEs under Douyu Yule’s Business Operation Agreements with the VIEs, the Company has determined that the carry value
of such receivables as of June 30, 2023 and September 30, 2023 was approximately their fair value, as the
receivables are payable upon requirement, and there was sufficient funding from the VIE’s own assets as well as advances
from the parent company to settle the payable balance as necessary upon demand.

As such, the Company believes that the values provided for
the “Amounts due from the VIEs pursuant to contractual arrangements” in our September Response, as updated below, reflects
the “fair value” of such asset in accordance with Section 2(a)(41) of the Investment Company Act.

 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.

The Company respectfully submits that it receives advice
from U.S. counsel for U.S. securities law matters. However, because the Company wishes to preserve privilege with respect to any discussions
or communications that the Company may have had with such U.S. counsel, the Company is not able to discuss the substance of such advice,
including whether or not the Company has received a legal opinion issued by counsel. If the staff would find it useful, the Company’s
U.S. counsel, Davis Polk, would be able to prepare an analysis to explain in writing to the staff, on behalf of the Company, its opinion
regarding Section 3(b)(1).

2
Under Section 2(a)(41) of the Investment Company Act, “value” as used in Section 3 is defined as: “ .
. . (A) as used in Sections 3, 5 and 12 of this title, (i) with respect to securities owned at the end of the last preceding fiscal quarter
for which market quotations are readily available, the market value at the end of such quarter; (ii) with respect to other securities
and assets owned at the end of the last preceding fiscal quarter, fair value at the end of such quarter, as determined in good faith
by the board of directors; and (iii) with respect to securities and other assets acquired after the end of the last preceding fiscal
quarter, the cost thereof . . .” Clauses (i) and (iii) would not apply to the “Amounts due from the VIEs pursuant to contractual
arrangements” because such assets are not securities for which market quotations are readily available, and were not acquired after
the end of the last preceding fiscal quarter.

3
“We recognize that there is no single methodology for determining the fair value of an investment because fair value
depends on the facts and circumstance of each investment, including the relevant market and market participants.” Good Faith
Determinations of Fair Value, Investment Company Act Release No. 34128 (December 3, 2020) (“Release 34128”). With
respect to good faith determinations of “fair value” under Section 2(a)(41) of the 1940 Act, the Commission has generally
referred to the definition of “fair value” in ASC 820-10-20: “Fair Value means ‘the price that would be received
to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date.’“
Release 34128, at note 67 (citing ASC 820-10-20).

 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.

Please see Appendix A attached hereto, which is blacklined
to show the updates to the calculations provided in our September Response, and Appendix B attached hereto, which is blacklined to
show the updates to the calculations provided in our November Response.

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.

The Company is submitting separately, on a confidential,
supplemental basis, its response to the Staff’s comment.

***

If you have
further questions or comments regarding, or require further information or clarification of, any of the responses provided in this letter
or if the Commission has any questions with respect to DouYu’s Annual Report on Form 20-F or DouYu’s Form 6-K filed
on November 21, 2023, please contact Li He at +852 2533-3306 (li.he@davispolk.com) of Davis Polk & Wardwell LLP.

Thank you for your time and attention.

    Yours sincerely,

    /s/ Mingming Su

    Name: Mingming Su

    Title: Chief Strategy Officer

    cc:

    Mr. Li He, Partner

    Davis Polk & Wardwell LLP

APPENDIX A

Updates to the calculations provided in our November Response
to the staff’s prior comments 4 and 5:

 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 September 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 September 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 September 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.

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).

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

As of June September 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.

• 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 engaged in the business of developing and providing products and services to create an integrated game-centric ecosystem
of livestreaming, video, graphic content and other interactive and community features. DouYu operates interactive gaming and entertainment
platforms on which users can enjoy immersive and interactive games and entertainment livestreaming, access a wide array of video and graphic
content, and participate in community events and discussions. The development