October 23, 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/A
           Amended on October 11, 2019
           CIK No. 0001776067

Dear Ms. Ni:

      We have reviewed your amended 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 on Form F-1/A, amended on October 11, 2019

Risk Factors, page 10

1.     We note your response to prior comment one, and reissue the comment in
part. Please
       revise to provide risk factor disclosure addressing the risks posed to
the company by
       virtue of its related party transactions. When you provide this risk
factor disclosure, please
       disclose the percentage of overall accounts receivable, accounts
payable, other payables,
       revenues, and selling and marketing expenses derived or expended by
virtue of the related
       party transactions.
 Lijia Ni
Oriental Culture Holding LTD
October 23, 2019
Page 2
Dilution, page 42

2.    We note your response to comment 2 however, we reiterate our comment.
Please revise
      your calculation of the amount of net tangible book value reported as of
June 30, 2019 to
      be consistent with the methodology described in your response.
Consolidated Financial Statements
Note 3 - Business Combinations, page F-45

3.    We note your response to our comment 5. Please also present the amounts
of revenue and
      earnings of HKDAEx since the acquisition date included in the
consolidated income
      statement for the reporting period, as required by ASC 805-10-50-2(h)(1).
4.    We note your response to comment 6. Please revise the value assigned to
the shares
      issued in the business acquisition, disclosed on page F-56, to be
consistent with the
      disclosure of $1,495,505 on page F-44.
The Unaudited Pro Forma Combined Financial Information As of and For Year Ended
Decmeber 31, 2018, page F-68

5.    We note your response to comments 11 and 12. Please expand your Note (a)
to describe
      how you calculated the adjustment of $665,078 to additional paid-in
capital. Adjustments
      reflected in the pro forma adjustments column for each specific
transaction should be
      factually supportable.
6.    We note your response to comments 12 and 13. Since the consummation of a
business
      combination is a major transaction and disclosure of pro forma financial
information
      would be material to an investor, please present the purchase price
allocation in a note to
      the pro forma information and reflect any adjustments to the pro forma
balance sheet and
      pro forma income statement, as necessary. State in the note if
adjustments were not
      material.
        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,
FirstName LastNameLijia Ni
                                                            Division of
Corporation Finance
Comapany NameOriental Culture Holding LTD
                                                            Office of Trade &
Services
October 23, 2019 Page 2
cc:       Jeffrey Li
FirstName LastName