Mail Stop 4631

                                                           October 2, 2018

Yun Cai
President
Tiburon International Trading Corp.
Xinkaicun, group 5, Weizigouzhen, Jiutai
Changchun, Jilin province, China 130519

       Re:      Tiburon International Trading Corp.
                Amendment No. 3 to Registration Statement on Form S-1
                Filed September 20, 2018
                File No. 333-223568

Dear Mr. Cai:

      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.

General

   1. We note your disclosure relating to the sale of 100,000 shares of common
stock to Dong
      Zheng on September 3, 2018. Please revise your registration statement,
where necessary,
      to reflect the transaction. By way of example and not limitation, please
revise the
      Security Ownership table on page 22 and disclosure relating to Item 701
of Regulation S-
      K on page 38.

Description of Our Business, page 13
Emerging Growth Company Status under the JOBS Act, page 15

   2. We note your disclosure that as an emerging growth company, you have made
the
      irrevocable election to not adopt the extended transition period for
complying with new
      or revised accounting standards under Section 107(b), as added by Section
102(b) of the
      JOBS ACT. However, we note that on page 35 you state you are deferring
adoption of
 Yun Cai
Tiburon International Trading Corp.
October 2, 2018
Page 2

        ASC 606, "Revenue from Contracts with Customers" (Topic 606) as an
emerging growth
        company. Given the apparent discrepancy between both these statements,
please advise
        or revise accordingly.

Exhibit 5.1

    3. We note that you are registering 6,000,000 shares of common stock
offered by you and
       100,000 shares of common stock offered by the selling stockholder.
Please have counsel
       opine on the primary offering and secondary offering. See Staff Legal
Bulletin No. 19.

        You may contact Ameen Hamady, Staff Accountant, at (202) 551-3891 or
Terence
O'Brien, Accounting Branch Chief, at (202) 551-3355 if you have questions
regarding comments
on the financial statements and related matters. Please contact Sergio Chinos,
Staff Attorney, at
(202) 551-7844 or Asia Timmons-Pierce, Special Counsel, at (202) 551-3754 with
any other
questions.


                                                           Sincerely,

                                                           /s/ Asia
Timmons-Pierce, for

                                                           Amanda Ravitz
                                                           Assistant Director
                                                           Office of
Manufacturing and
                                                           Construction