Mail Stop 4631

                                                              October 19, 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. 4 to Registration Statement on Form S-1
                Filed October 5, 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. Unless
we note
otherwise, our references to prior comments are to comments in our October 2,
2018 letter.

Plan of Distribution, page 12

   1. It appears that you have inadvertently reflected a share price of $0.30
for the selling
      stockholders. Please revise this section and selling shareholder plan of
distribution
      section to clarify that the shares will be sold at the fixed price of
$0.03 for the duration of
      the offering.

Exhibit 5.1

   2. We note your response to our prior comment 3. Please have counsel revise
the legal
      opinion to opine, if true, that the 100,000 shares of common stock being
offered by the
      selling stockholders are legally issued, fully paid, and non-assessable.
Please refer to
      Section II.B.2.h of Staff Legal Bulletin No. 19.
 Yun Cai
Tiburon International Trading Corp.
October 19, 2018
Page 2

        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