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May 12, 2020
Lijia Ni
Chief Financial Officer
Oriental Culture Holding LTD
Room 1512 Block 4 Kang Yuan Zhihui Gang
No 50 Jialingjiang East Road
Jiangsu Province 210000
PRC
Re:Oriental Culture Holding LTD
Registration Statement on Form F-1/A
Amended on May 1, 2019
File No. 333-234654
Dear Ms. Ni:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 4 to Form F-1 Filed on May 1 2020
Notes to the Consolidated Financial Statements
Note 2 - Summary of Significant Accounting Policies
Revenue Recognition , page F-13
1.With respect to the listing service fee, please describe your basis of recognizing revenue
"ratably over time" and explain to us your consideration of ASC 606-10-25-31 through
25-37.
2.Regarding your marketing services, please clarify your disclosure and tell us:

 FirstName LastNameLijia Ni
 Comapany NameOriental Culture Holding LTD
 May 12, 2020 Page 2
 FirstName LastName
Lijia Ni
Oriental Culture Holding LTD
May 12, 2020
Page 2
•if you provide several services to customers under a contract and if so, whether you
consider each service to be separately identifiable from the others in the contract.  If
applicable, tell us how you allocate the transaction price to each service.  In this
regard, we note you provide services such as consultation, supporting, legal
protection etc.  Please refer to ASC 606-10-25 and ASC 606-10-32 in your response.
•your basis for amortizing fees "based on the service period."  Provide us your
analysis by each type of marketing service including but not limited to the promotion
services to place ads on various websites.  Refer us to the supporting authoritative
accounting literature that is the basis for your policy.
Item 8. Exhibits and Financial Statement Schedules , page II-2
3.Please provide the auditor's consent for the report dated September 13, 2019, relating to
the audited financial statements of HKDAEx as of December 31, 2018.
            You may contact Christie Wong, Staff Accountant, at 202-551-3684, or Robert S.
Littlepage, Accounting Branch Chief, at 202-551-3361, if you have questions regarding
comments on the financial statements and related matters.  Please contact Paul Fischer, Staff
Attorney, at 202-551-3415, or Celeste M. Murphy, Legal Branch Chief, at 202-551-3257, with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jeffrey Li