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                            April 30, 2020

       Wenxian Fan
       Chief Executive Officer
       Pony Group Inc.
       Engineer Experiment Building, A202
       7 Gaoxin South Avenue, Nanshan District,
       Shenzhen, Guangdong Province,
       People's Republic of China

                                                        Re: Pony Group Inc.
                                                            Amendment No. 4 to
Registration Statement on Form S-1
                                                            Filed April 23,
2020
                                                            File No. 333-234358

       Dear Ms. Fan:

             We have reviewed your amended registration statement 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.
Unless we note
       otherwise, our references to prior comments are to comments in our March
30, 2020 letter.

       Amendment No. 4 to Registration Statement on Form S-1 filed April 23,
2020

       Dilution, page 27

   1.                                                   We note your
computations of net tangible book value prior to and after the offering
                                                        include intangible
assets. Please revise your disclosures to exclude these amounts from
                                                        your computations
accordingly.
       General

   2.                                                   We note your response
to our prior comment 1. Please address more specifically how
                                                        COVID-19 has impacted
your services, explaining the extents to which you have
 Wenxian Fan
Pony Group Inc.
April 30, 2020
Page 2
         reopened your business and demand has returned for your business
following your office
         closure that ended on February 10, 2020. Also expand your disclosure
to explain any
         current travel restrictions between Guangdong Province and Hong Kong.
In addition
         discuss your office shutdown between January 19, 2020 and February 10,
2020 in your
         Prospectus Summary, for example in a Recent Developments section.
Refer to CF
         Disclosure Guidance: Topic No. 9 for further guidance, available at
         https://www.sec.gov/corpfin/coronavirus-covid-19.

         As a related matter, please further describe, and quantify to the
extent possible, any known
         trends and uncertainties that have had, or that you reasonably expect
will have, a material
         favorable or unfavorable impact on revenue or results of operations,
in light of the impact
         of COVID-19 in your business.
        You may contact Melissa Gilmore at 202-551-3777 or Melissa Raminpour at
202-551-
3379 if you have questions regarding comments on the financial statements and
related
matters. Please contact Susan Block at 202-551-3210 or John Dana Brown at
202-551-3859
with any other questions.



FirstName LastNameWenxian Fan                                  Sincerely,
Comapany NamePony Group Inc.
                                                               Division of
Corporation Finance
April 30, 2020 Page 2                                          Office of
Finance
FirstName LastName