July 18, 2019

Kun Dai
Chief Executive Officer
Uxin Limited
2-5/F, Tower E, LSHM Center
No. 8 Guangshun South Avenue
Chaoyang District
Beijing, 100102
People's Republic of China

       Re: Uxin Limited
           Form 20-F for Fiscal Year Ended December 31, 2018
           Filed April 29, 2019
           File No. 001-38527

Dear Mr. Dai:

       We have reviewed your filing and have the following comments. In some of
comments, we may ask you to provide us with information so we may better
understand your

       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

       After reviewing your response to these comments, we may have additional

Form 20-F for Fiscal Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Selected Statements of Operations Items
Revenues, page 86

1.    We note your disclosure on page F-27 that you do not charge transaction
      services fees to car dealers for certain transactions without financing
solutions attached.
      However, on page F-23 of your Form F-1 filed June 22, 2018, you disclosed
you did
      charge a fee for these transactions. Please tell us and address in future
filings the
        Revise to disclose the reason for the change in fees, including whether
the change is
          permanent or temporary.
 Kun Dai
FirstName LastNameKun Dai
Uxin Limited
Comapany NameUxin Limited
July 18, 2019
July 18, 2019 Page 2
Page 2
FirstName LastName
            Clearly disclose throughout that you do not charge a transaction
facilitation fee in
            arrangements where the buyer does not utilize your loan
facilitation services.
           Revise disclosure on page 91 to discuss the impact this change has
had on your
            revenues during the reported periods.
         Refer to Item 5.A of Form 20-F.
Gains/(losses) from guarantee liability, page 88

2.       Please tell us how you considered disclosure of the notional balance
or percentage of your
         notional balance of your guarantee obligation by current loan to value
categories, as trends
         in this metric would appear to also impact the overall losses incurred
as a result of your
         guarantee obligation. Refer to Item 5.E.1.d of Form 20-F. Please
advise and revise future
         filings as applicable.
Contractual Obligations, page 108

3.       Please tell us why you do not include amounts due pursuant to your
convertible debt in
         your contractual obligations table or explain why it is not included
in a note to the table.
         Refer to Item 5.f of Part I to Form 20-F.
Consolidated Financial Statements
Note 2.19. Revenue recognition, page F-26

4.       You disclose that you do not charge transaction facilitation services
fees to car dealers for
         certain transactions without financing solutions attached. Please
address the following:
           Disclosure on page 87 indicates that you charge a fee for each car
sold through your
             2C business. Please reconcile this apparent inconsistency.
           Clarify your disclosure to clearly state whether you provide
transaction facilitation
             services and warranties for transactions completed through your
platform that are not
             charged a fee. Clarify how you account for such services provided
in these
           Tell us how you consider these transactions when allocating revenue
to your
             performance obligations in arrangements where you do charge a fee.
         Refer to ASC 606-10-32-28.
Note 6. Loan Recognized as a Result of Payment Under the Guarantee, page F-39

5.       Please revise future filings to reflect any additional required
provision for existing loans,
         any adjustments due to settlements from the Borrowers or other
recoveries and any
         adjustments due to the guarantees being bought out separately in the
disclosure of the
         activity in the allowance for loan losses. Refer to ASC
6.       Please revise future filings to present the balance of loans
recognized as a result of
         payment under the guarantee by monitored credit quality indicator.
Refer to ASC 310-10-
 Kun Dai
Uxin Limited
July 18, 2019
Page 3

        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 Rebekah Lindsey, Staff Accountant at (202) 551-3303 or
Craig Wilson,
Senior Assistant Chief Accountant at (202) 551-3226 if you have any questions.

FirstName LastNameKun Dai
                                                          Division of
Corporation Finance
Comapany NameUxin Limited
                                                          Office of Information
July 18, 2019 Page 3                                      and Services
FirstName LastName