February 6, 2019

Zheng Huang
Chairman of the Board of Directors and Chief Executive Officer
Pinduoduo Inc.
28/F, No. 533 Loushanguan Road, Changning District
Shanghai, 200051
People's Republic of China

       Re: Pinduoduo Inc.
           Registration Statement on Form F-1
           Filed February 5, 2019
           File No. 333-229523

Dear Mr. Huang:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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.

Registration Statement on Form F-1 filed February 5, 2019

Limitations on Obligations and Liability, page 181

1.     We note that your disclosure in this section appears to conflict.
Specifically, on page 182
       you state that the jury trial waiver provision in the deposit agreement
"does not apply to
       claims against us made under the federal securities laws." Yet the
disclosure under "Jury
       Trial Waiver" on the same page states that "[t]he deposit agreement
provides that each
       party to the deposit agreement (including each holder, beneficial owner
and holder of
       interests in the ADRs) irrevocably waives, to the fullest extent
permitted by applicable
       law, any right it may have to a trial by jury in any lawsuit or
proceeding against us or the
       depositary arising out of or relating to our shares, the ADSs or the
deposit agreement,
       including any claim under the U.S. federal securities laws" (emphasis
added). Please
 Zheng Huang
Pinduoduo Inc.
February 6, 2019
Page 2
      revise your disclosure to clearly state whether the jury trial waiver
provision applies to
      claims under the U.S. federal securities laws. If the jury trial waiver
provision does apply
      to claims under the U.S. federal securities laws, disclose, if true, that
by agreeing to the
      provision, investors will not be deemed to have waived your or the
depositary's
      compliance with the federal securities laws and the rules and regulations
promulgated
      thereunder. Finally, provide risk factor disclosure related to the
arbitration and jury trial
      waiver provisions, including but not limited to the enforceability of the
      provisions, increased costs to bring a claim, limited access to
information and other
      imbalances of resources between the company and shareholders, and that
these provisions
      can discourage claims or limit shareholders' ability to bring a claim in
a judicial forum
      that they find favorable.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Katherine Bagley, Staff Attorney, at (202) 551-2545 or
Mara Ransom,
Assistant Director, at (202) 551-3720 with any questions.



                                                             Sincerely,
FirstName LastNameZheng Huang
                                                             Division of
Corporation Finance
Comapany NamePinduoduo Inc.
                                                             Office of Consumer
Products
February 6, 2019 Page 2
cc:       Z. Julie Gao
FirstName LastName