UNITED STATES
                                   SECURITIES AND EXCHANGE COMMISSION
                                             WASHINGTON, D.C. 20549-3628


     DIVISION OF
CORPORATION FINANCE


                                                                December 4,
2020

  Via E-Mail
  Don S. Williams, Esq.
  Hogan Lovells International LLP
  Suite 1804-1808, Park Place
  1601 Nanjing Road West
  Jing An District
  Shanghai 200040

          Re:     Acorn International, Inc.
                  Amendment No. 1 to Schedule 13E-3
                  Filed by Acorn International, Inc., First Ostia Port Ltd.,
Second Actium Coin
                      Ltd., Robert W. Roche, Ritsuko Hattori-Roche, Catalonia
Holdings, LLC
                      and Bireme Limited
                  Filed on November 27, 2020
                  File No. 5-83555

  Dear Mr. Williams:

       We have reviewed the above filing and related response letter and have
the following
  comments.

  Schedule 13E-3 Exhibit (a)-(1) Preliminary Proxy Statement of the Company

  1.      We note your response to prior comment 7. We acknowledge that the
Company is a
          foreign private issuer and is not required to, and does not, file
quarterly reports under the
          Exchange Act. However, given that the Company has furnished its
quarterly earnings
          release, and in light of the guidance referred to in our prior
comment and the information
          provided in your response, we are unable to agree that the Company is
not required to
          include such information in the Rule 13e-3 disclosure materials
disseminated to
          shareholders.

                                                *       *       *

         Please direct any questions to me at (202) 551-3444. You may also
contact me via
  facsimile at (202) 772-9203. Please send all correspondence to us at the
following ZIP code:
  20549-3628.
 Don S. Williams, Esq.
Hogan Lovells International LLP
December 4, 2020
Page 2

                                  Sincerely,

                                  /s/ Perry J. Hindin

                                  Perry J. Hindin
                                  Special Counsel
                                  Office of Mergers & Acquisitions