April 22, 2020

LiMing Yung
Chief Financial Officer
Pingtan Marine Enterprise Ltd.
18-19/F, Zhongshan Building A
No. 154 Hudong Road
Fuzhou, P.R.C. 350001

       Re: Pingtan Marine Enterprise Ltd.
           Form 10-K for the Fiscal Year Ended December 31, 2019
           Filed March 16, 2020
           File No. 001-35152

Dear Mr. Yung:

       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 10-K for the Fiscal Year Ended December 31, 2019

Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies, Revenue Recognition, page
F-14

1.    Please tell us where you provided the quantitative disaggregation of
revenue disclosures
      based on how economic factors affect the nature, amount, timing and
uncertainty of
      revenue recognition and cash flows. Refer to ASC 606-10-50-5 and 50-7.
Note 4. Inventories, page F-19

2.    Reference the disclosure that you have $25 million of frozen fish and
marine catches work
      in progress at December 31, 2019 compared to none in the prior year.
Revise future
      filings to briefly describe the nature of "work in progress" and, as
applicable, explain the
      reasons for material changes in the balance when compared to the prior
year in MD&A.
      Refer to Instruction 4 of Item 303(a) of Regulation S-K. Provide us with
your proposed
 LiMing Yung
Pingtan Marine Enterprise Ltd.
April 22, 2020
Page 2
      revised disclosures.
Note 9. Property, Plant, and Equipment, page F-21

3.    We see that you continue to have 37 vessels located in the Arafura Sea in
Indonesia that
      are not in operation due to the moratorium and that you expect the
carrying value of the
      fishing vessels to be recoverable based on the undiscounted future cash
flows, which
      includes the impact of the moratorium. Given the extended period of the
moratorium and
      the unknown timing of when fishing will resume in Indonesia, provide us
with your
      impairment analysis under ASC 360-10-35-17. In addition, please revise
future filings
      to include enhanced disclosure about your impairment analysis, estimates
made, and
      factors that cause the estimate to be sensitive to change. Refer to ASC
275-10-50-8.
       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 Kristin Lochhead, Staff Accountant, at (202) 551-3664 or
Kate Tillan,
Senior Accountant, at (202) 551-3604 with any questions.



                                                          Sincerely,
FirstName LastNameLiMing Yung
                                                          Division of
Corporation Finance
Comapany NamePingtan Marine Enterprise Ltd.
                                                          Office of Life
Sciences
April 22, 2020 Page 2
cc:       Yuri Mikulka
FirstName LastName