February 20, 2020

Jacky Jinbo Wang
Chief Financial Officer
Ruhnn Holding Ltd
F, Building 1, Blue Collar Garment Industrial Park
7-1 North Hong Pu Road
Yu Hang District, Hangzhou 311100
People's Republic of China

       Re: Ruhnn Holding Ltd
           Form 20-F for the Fiscal Year Ended March 31, 2019
           Filed July 30, 2019
           File No. 001-38852

Dear Mr. Wang:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 20-F filed July 30, 2019

Operating Results
Key Components of Results of Operations, page 67

1.    You disclose that net revenues as a percentage of your total GMV has
decreased due to an
      increase in the proportion of your net revenues generated from services.
In this regard we
      note that your net revenues for services under the platform model as a
percentage of GMV
      of third-party online stores decreased significantly from fiscal year
2018 to 2019. Please
      tell us your consideration of disclosing the drivers behind this
decrease.
Liquidity and Capital Resources, page 77

2.    Please disclose the amount of cash and cash equivalents and restricted
cash disaggregated
      by currency denomination as of the most recent balance sheet date in each
jurisdiction.
 Jacky Jinbo Wang
Ruhnn Holding Ltd
February 20, 2020
Page 2
Combined and Consolidated Statements of Comprehensive Loss, page F-4

3.       On page 70 you state other operating income/(loss) consists primarily
of the income or
         losses from disposing your excess and obsolete raw materials; however,
on page F-17 you
         state cost of products includes inventory write-downs. Please tell us
why the cost
         of disposing your excess and obsolete raw materials is not included in
cost of product
         sales.
Combined and Consolidated Statements of Cash Flows, page F-6

4.       Note 8 to the financial statements discloses that you capitalized
Buildings in the amount
         of RMB125,692,281 during the year ended March 31, 2019. Your cash
flows for
         investing activities for the same period reflects expenditures of only
RMB6,820,391.
         Please explain to us how the buildings were acquired and why your
statement of cash
         flows does not reflect cash used for this investing activity.
       In closing, 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 Tony Watson at (202) 551-3318 or Donna Di Silvio at (202)
551-
3202 with any questions.



FirstName LastNameJacky Jinbo Wang                            Sincerely,
Comapany NameRuhnn Holding Ltd
                                                              Division of
Corporation Finance
February 20, 2020 Page 2                                      Office of Trade &
Services
FirstName LastName