April 17, 2020

Jianmin Zhang
Chief Executive Officer
Fovea Jewelry Holdings Ltd.
30 N. Gould Street, Suite 2984
Sheridan, Wyoming 82801

       Re: Fovea Jewelry Holdings Ltd.
           Registration Statement on Form 10
           Filed March 23, 2020
           File No. 000-56156

Dear Mr. Zhang:

       We have reviewed your filing 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10 Filed March 23, 2020

Business
Recent Developments, page 4

1.    Please revise your disclosure to discuss the March 20, 2020 share
exchange transaction
      and recapitalization through which you acquired Gold Shiny International
Limited
      and Gold Shiny (Asia) Limited, and clarify that the business of Gold
Shiny reflects the
      current business of your company.
Overview, page 4

2.    Please revise your disclosure to clearly describe the current operations
of your business,
      including whether your business and website are operational, as we note
your disclosure
      throughout that you have completed only the perliminary stages of a
business plan, have
      no products ready to sell, and do not have a history of earnings. If your
business is not
      currently operational, please revise to clearly state this and remove any
implication that
 Jianmin Zhang
FirstName LastNameJianmin Zhang
Fovea Jewelry Holdings Ltd.
Comapany NameFovea Jewelry Holdings Ltd.
April 17, 2020
April 2 2020 Page 2
Page 17,
FirstName LastName
         you are operational or currently hold inventory. If your business is
operational, please
         revise your disclosure accordingly and clarify the operational status
of your business and
         website how you fulfill orders, whether by carring inventory,
operating through vendors
         or otherwise.
Competition, page 5

3.       We note your statement that if dealers and sellers participate less in
your auctions, you
         may attract fewer buyers and your revenue could decrease. Please
describe how auctions
         are involved in your business, if at all.
Risk Factors
There is uncertainty regarding our ability to continue as a going concern...,
page 6

4.       We note your statement that you have incurred net losses of $10 from
your inception on
         January 31, 2019. This is not consistent with your financial
statements or your date of
         inception. Please revise accordingly.
We may become subject to legal proceedings..., page 9

5.       We note your disclosure that you maintain liability insurance
coverage. Please reconcile
         this with your statement on page five that you do not maintain any
insurance.
Because we will likely have fewer than three hundred shareholders of record...,
page 10

6.       We note your disclosure on page 23 that as of March 18, 2020, you had
1,292 holders of
         common stock of record. Please tell us why you believe it is likely
that you will have
         fewer than three hundred shareholders of record.
Anti-takeover effects of certain provisions of Wyoming law..., page 13

7.       Please disclose at what point you would become subject to Wyoming's
control share law.
Management's Discussion and Analysis of Financial Condition and Results of
Operations., page
14

8.       Given the recent Coronavirus outbreak in China and other countries,
please include
         in management's current outlook for the near future whether you expect
the outbreak to
         have a material impact on your revenues in your current or future
financial periods, and if
         so, disclose this in your filing. If the outbreak has required you to
close your operations,
         please disclose that information and when you expect to reopen your
operations.
 Jianmin Zhang
FirstName LastNameJianmin Zhang
Fovea Jewelry Holdings Ltd.
Comapany NameFovea Jewelry Holdings Ltd.
April 17, 2020
April 3 2020 Page 3
Page 17,
FirstName LastName
Item 2. Financial Information
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Limited Business History; Need for Additional Capital , page 15

9.       We note your disclosure that there is no historical financial
information about the
         Company upon which to base an evaluation of your performance, and that
state you are a
         development stage corporation, which has no significance in current
U.S. GAAP, and
         have not generated any revenues from your business. You also disclose
that your business
         is subject to risks, including possible delays in exploration and/or
development. These
         statements do not appear to be consistent with your financial
statements. Please revise to
         discuss the status of your operations as of and for the year ended
December 31, 2019.

Liquidity and Capital Resources, page 16

10.      We note your disclosure that you have sufficient cash on hand to
commence your 12-
         month plan of operation. You also state that you will need to raise
funds to commence
         your 12-month plan of operation and fund your ongoing operational
expenses. Please
         reconcile these two statements that appear to be contradictory.
11.      Please tell us your consideration of discussing your plan of operation
for the next 12
         months, including your sources of liquidity and your capital
requirements.
New Accounting Pronouncements, page 17

12.      Your disclosure in the 3rd paragraph regarding the adoption of ASU
2014-09 is
         inconsistent with your disclosure in the last paragraph on page 17 and
your accounting
         policy disclosed on page F-9. Please revise. In addition, you disclose
that you are
         assessing the impact of ASU 2016-02 (ASC 842) which was effective for
periods
         beginning after December 15, 2018. Please clarify whether you adopted
ASC 842 as
         of December 1, 2019 and the impact on your financial statements.
Security Ownership of Certain Beneficial Owners and Management., page 19

13.      In the beneficial ownership chart you disclose total shares owned by
certain beneficial
         owners and management as 100,000,000 common shares when their are
         10,090,974 common shares outstanding. Also, in footnote 1 the
ownership holdings you
         disclose for Mr. Zhang do not match the numbers in the beneficial
ownership chart.
         Please reconcile your disclosures.
Directors, Executive Officers., page 20

14.      In your chart you disclose that Mr. Zhang is 53 years old but in your
accompanying
         narrative you state he is 72 years old. Please reconcile your
disclosures.
 Jianmin Zhang
Fovea Jewelry Holdings Ltd.
April 17, 2020
Page 4
Consolidated Balance Sheets, page F-3

15.      The amount of retained earnings at December 31, 2019 differs from the
amount presented
         on the consolidated statements of changes in stockholders' equity
(deficit). Please revise
         or advise.
Exhibits

16.      We note that Exhibit 3.4 is labeled as your bylaws. However, this
exhibit appears to be an
         amendment to your Articles of Domestication reflecting the reverse
share split. Please file
         the bylaws as an amendment to the Form 10.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Amy Geddes at 202-551-3304 or Bill Thompson at
202-551-3344 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Scott Anderegg at 202-551-3342 or Erin Jaskot at 202-551-3442 with any
other
questions.



FirstName LastNameJianmin Zhang                               Sincerely,
Comapany NameFovea Jewelry Holdings Ltd.
                                                              Division of
Corporation Finance
April 17, 2020 Page 4                                         Office of Trade &
Services
FirstName LastName