April 13, 2020

Panagiotis Tolis
Chief Investor Relations Officer
Elvictor Group, Inc.
30 Wall Street (8th floor)
New York, NY 10005

       Re: Elvictor Group, Inc.
           Post-effective Amendment No. 5 to Registration Statement on Form S-1
           Filed April 7, 2020
           File No. 333-225239

Dear Mr. Tolis:

       We have reviewed your post-effective amendment 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 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.

Post-Effective Amendment No. 5 to Form S-1

Prospectus Summary, page i

1.     We reissue comment 2. Please revise your prospectus to consistently
describe this
       offering as a resale transaction and state you will receive no proceeds
from this offering.
Where You Can Find More Information, page 37

2.     Notwithstanding that we note you have filed your annual report on Form
10-K for fiscal
       year 2019 on April 3, 2020, we reissue comment 3. Please revise this
section to remove
       references to documents incorporated by reference.
Signatures, page II-5

3.     We reissue comment 4. Please provide the signatures for your principal
financial officer
 Panagiotis Tolis
Elvictor Group, Inc.
April 13, 2020
Page 2
         or CFO, and your principal accounting officer or controller, as
required by the Instructions
         to the Signatures on Form S-1. If a person is acting in more than one
capacity, please
         indicate each capacity in which the person signs.
        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.

       Please contact Jacqueline Kaufman at 202-551-3797 or Mara Ransom at
202-551-3264
with any other questions.



FirstName LastNamePanagiotis Tolis                             Sincerely,
Comapany NameElvictor Group, Inc.
                                                               Division of
Corporation Finance
April 13, 2020 Page 2                                          Office of Trade
& Services
FirstName LastName