December 13, 2024

Yang Hu
Chief Financial Officer
Yalla Group Limited
#234, Building 16
Dubai Internet City
PO BOX 501913
Dubai, United Arab Emirates

       Re: Yalla Group Limited
           Form 20-F for the Period Ended December 31, 2023
           File No. 001-39552
Dear Yang Hu:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 20-F for the Period Ended December 31, 2023
Conventions that Apply to this Annual Report on Form 20-F, page 1

1.     We note from your disclosure on page 1 that you exclude Hong Kong and
Macau
       from your definition of    PRC    or    China    for the purpose of your
annual report. In
       future filings, please revise to remove the exclusion of Hong Kong and
Macau from
       such definition. Clarify that all the legal and operational risks
associated with having
       operations in the People   s Republic of China (PRC) also apply to
operations in Hong
       Kong and Macau. In this regard, ensure that your disclosure does not
narrow risks
       related to operating in the PRC to mainland China only. Where
appropriate, you may
       describe PRC law and then explain how law in Hong Kong and Macau differs
from
       PRC law and describe any risks and consequences to the company
associated with
       those laws.
 December 13, 2024
Page 2

Part I.
Item 3. Key Information, page 3

2.     In future filings, at the onset of Part I please disclose prominently
that you are not a
       Chinese operating company but a Cayman Islands holding company with
subsidiaries
       based in China.
3.     We note your discussion of legal and operational risks on page 3 in Part
I, Item 3.
       Please expand your discussion in future filings to clearly disclose
these risks could
       cause the value of your securities to significantly decline or become
worthless and
       address how recent statements and regulatory actions by China   s
government, such as
       those related to data security or anti-monopoly concerns, have or may
impact the
       company   s ability to conduct its business, accept foreign investments,
or list on a U.S.
       or other foreign exchange.
4.     In future filings, please provide a clear description of how cash is
transferred through
       your organization. Disclose your intentions to distribute earnings.
Quantify any cash
       flows and transfers of other assets by type that have occurred between
the holding
       company and the subsidiaries, and the direction of transfer. Quantify
any dividends or
       distributions that a subsidiary has made to the holding company and
which entity
       made such transfer, and their tax consequences. Similarly quantify
dividends or
       distributions made to U.S. investors, the source, and their tax
consequences. Your
       disclosure should make clear if no transfers, dividends, or
distributions have been
       made to date. Describe any restrictions on foreign exchange and your
ability to
       transfer cash between entities, across borders, and to U.S. investors.
Describe any
       restrictions and limitations on your ability to distribute earnings from
the company,
       including your subsidiaries, to the parent company and U.S. investors.
5.     In future filings, please disclose each permission or approval that you
or your
       subsidiaries are required to obtain from Chinese authorities to operate
your business
       and to offer the securities being registered to foreign investors. State
whether you or
       your subsidiaries are covered by permissions or approvals and whether
any
       permissions or approvals have been denied. Please also describe the
consequences to
       you and your investors if you or your subsidiaries: (i) do not receive
or maintain such
       permissions or approvals, (ii) inadvertently conclude that such
permissions or
       approvals are not required, or (iii) applicable laws, regulations, or
interpretations
       change and you are required to obtain such permissions or approvals in
the future.
Risk Factors, page 4

6.     In future filings, in your risk factor summary please disclose the risks
that your
       corporate structure and having significant operations in China poses to
investors. In
       particular, describe the significant regulatory, liquidity, and
enforcement risks with
       cross-references to the more detailed discussion of these risks in Risk
Factors. For
       example, specifically discuss risks arising from the legal system in
China, including
       risks and uncertainties regarding the enforcement of laws and that rules
and
       regulations in China can change quickly with little advance notice; and
the risk that
       the Chinese government may intervene or influence your operations at any
time, or
       may exert more control over offerings conducted overseas and/or foreign
investment
 December 13, 2024
Page 3

       in China-based issuers, which could result in a material change in your
operations
       and/or the value of the securities you are registering for sale.
Acknowledge any risks
       that any actions by the Chinese government to exert more oversight and
control over
       offerings that are conducted overseas and/or foreign investment in
China-based
       issuers could significantly limit or completely hinder your ability to
offer or continue
       to offer securities to investor and cause the value of such securities
to significantly
       decline or be worthless.
7.     In light of recent events indicating greater oversight by the Cyberspace
       Administration of China (CAC) over data security, please add risk factor
disclosure in
       future filings to explain how this oversight impacts your officers and
directors and to
       what extent you believe that you are compliant with the regulations or
policies that
       have been issued by the CAC to date.
8.     We note your disclosure on page 27 that certain of your directors and
executive
       officers reside within China, and a portion of your assets and the
assets of those
       persons are located within China. In future filings, please identify any
directors,
       officers, or members of senior management located in the PRC/Hong Kong.
       Additionally, please include a separate    Enforceability    section
that addresses
       whether or not investors may bring actions under the civil liability
provisions of the
       U.S. federal securities laws against you, your officers or directors who
are residents of
       a foreign country, and whether investors may enforce these civil
liability provisions
       when your assets, officers, and directors are located outside of the
United States.
Consolidated Financial Statements
Note 11. Income Tax, page F-26

9.     We note "[b]ased on a review of surrounding facts and circumstances, the
Group does
       not believe that it is more likely than not that its operations outside
the PRC should be
       considered a resident enterprise for PRC tax purposes." Please explain
to us and
       disclose:
           these facts and circumstances considered by management;
           whether or not this issue has been considered by the PRC taxing
authority; and
           the financial ramifications if the Company were to be considered a
resident
           enterprise for PRC tax purposes.
       Please provide us with the disclosure you will make in future filings.
10.    Please discuss here and in MD&A the circumstances that resulted in the
increase in
       deferred tax assets in 2023. Describe what is creating the increase in
net operating loss
       carry forwards, including the impact of pricing of any intercompany
transactions.
        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.
 December 13, 2024
Page 4

      Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage
at 202-
551-3361 with any questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Technology