June 6, 2019

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
           Draft Registration Statement on Form F-1
           Filed on May 13, 2019
           CIK No. 0001776067

Dear Ms. Ni:

       We have reviewed your draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement Submitted on May 13, 2019

Prospectus Summary, page 1

1.     Please clarify at the beginning of your business section that the
investor would be
       investing in a holding company, with operations conducted via its
subsidiaries.
Corporate History and Structure, page 3

2.     Please revise your organizational chart on page 3 to reflect the
post-offering ownership
       structure of the company, including the percentage held by Kong Aimin
and Gao Huajun
       and the public shareholders upon completion of the offering.
 Lijia Ni
FirstName LastNameLijiaLTD
Oriental Culture Holding Ni
Comapany NameOriental Culture Holding LTD
June 6, 2019
June 6, 2019 Page 2
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FirstName LastName
We will incur increased costs as a result of being a public company, page 37

3.       To the extent determinable, please revise to provide an estimate of
the increased costs
         associated with being a public company.
Dilution, page 41

4.       Please revise your calculation of net tangible book value to exclude
intangible assets and
         deferred offering costs.
Revenues, page 47

5.       We note that marketing service fees represent roughly 70% of your
revenues. Please
         revise at footnote three briefly to provide more detail as to how the
marketing service fees
         are determined.
Introduction of Collectibles Trading in China, page 57

6.       Please clarify what the chart on this page represents. Include all
appropriate legends and
         labels.
Our Customers, page 69

7.       Please clarify whether there are any criteria in place for determining
customer
         qualifications to open and activate a trading account.
PRC Regulations, page 74

8.       We note that you have not included disclosures here or in risk factors
concerning
         regulations related to internet information security and privacy
protection, including, for
         example, the Regulation on the Internet Security Supervision and
Inspection by Public
         Security Organs, effective November 1, 2018. Please advise or revise.
United States Federal Income Tax Considerations, page 100

9.       We note that your discussion of United States Federal Income Tax
Considerations makes
         no reference to the opinion of Garvey Schubert Barer that you intend
to file as Exhibit 8.1
         in a subsequent amendment. Please advise or revise.
Consolidated Financial Statements, page F-3

10.      Please update the financial information to include interim financial
statements for period
         ended March 31, 2019.
11.      In light of the disclosure indicating you commenced operations in
March 2018, it is
         unclear why the period covered by your income statement and statement
of cash flows is
         the entire year ended December 31, 2018. Please stipulate the specific
period covered by
 Lijia Ni
FirstName LastNameLijiaLTD
Oriental Culture Holding Ni
Comapany NameOriental Culture Holding LTD
June 6, 2019
June 6, 2019 Page 3
Page 3
FirstName LastName
         your income statement and statement of cash flows or advise us. It may
also be necessary
         for your auditor to revise the wording of their report.
12.      Please provide condensed financial statements of the registrant,
pursuant to Rule 5-04 of
         Regulation S-X, or advise us. The financial statements should provide
the information
         required by Rule 12-04 of Regulation S-X.
Notes to Consolidated Financial Statements
Note 2 - Summary of Significant Accounting Policies, page F-14

13.      Please disclose the estimated useful lives and residual value of
electronic equipment and
         server room equipment, respectively.
Note 3 - Variable interest entity, page F-21

14.      The calculation of the net assets of your VIE, disclosed on page F-22,
should be revised to
         deduct total liabilities from total assets.
Note 15 - Subsequent Event, page F-31

15.      We note that you acquired HKDAEx Limited subsequent to year end.
Please provide the
         most recent audited financial statements of the acquired entity and
prepare the related pro
         forma information as required by Rule 8-04 and Rule 8-05 of Regulation
S-X,
         respectively. In addition, please reflect such transaction in the
capitalization table on page
         40, if applicable.
16.      We note you acquired China International Assets and Equity of Artworks
Exchange
         Limited on May 7, 2019. Please provide audited year-end and unaudited
interim financial
         statements, pursuant to Rule 8-04 of Regulation S-X, and pro forma
financial information
         to give effect to the acquisition, pursuant to Rule 8-05 of Regulation
S-X, or explain to us
         why it is not necessary for you to do so.
General

17.      We note references to third-party market data within your prospectus,
including, for
         example, a reference at page 1 to statistics derived by the Ministry
of Commerce of the
         People's Republic of China, and to the "2017 China Private Wealth
Report" at page 56.
         Please provide us with copies of any materials that support
third-party statements, clearly
         cross-referencing a statement with the underlying factual support.
        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.
 Lijia Ni
Oriental Culture Holding LTD
June 6, 2019
Page 4



                                            Sincerely,
FirstName LastNameLijia Ni
                                            Division of Corporation Finance
Comapany NameOriental Culture Holding LTD
                                            Office of Telecommunications
June 6, 2019 Page 4
cc:       Jeffrey Li
FirstName LastName