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                             November 17, 2021

       Tak Ching Poon
       Chief Executive Officer
       ALE Group Holding Ltd
       Unit 1005, 10/F, Tower A
       Mandarin Plaza, 14 Science Museum Road
       Tsim Sha Tsui, Hong Kong

                                                        Re: ALE Group Holding
Ltd
                                                            Post-Effective
Amendment No. 4 to Registration Statement on Form F-1
                                                            Filed October 18,
2021
                                                            File No. 333-239225

       Dear Mr. Poon:

              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. 4 to Form F-1 filed October 18, 2021

       Cover Page

   1.                                                   Please provide on the
prospectus cover page a description of how cash is transferred
                                                        through your
organization and disclosure regarding your intentions to distribute earnings
                                                        or settle amounts owed
under the VIE agreements. State whether any transfers, dividends,
                                                        or distributions have
been made to date.
       Recent Regulatory Development in PRC, page 6

   2.                                                   Please disclose whether
you are required to obtain any approvals to offer securities to
                                                        foreign investors,
whether you have received such approvals and the consequences to you
                                                        and your investors if
you do not receive or maintain the approvals, inadvertently conclude
 Tak Ching Poon
ALE Group Holding Ltd
November 17, 2021
Page 2
         that such approvals are not required, or applicable laws, regulations,
or interpretations
         change and you are required to obtain approval in the future.
Risk Factors, page 11

3.       We note from the audit opinion that you have a U.S. based auditor that
is registered with
         the PCAOB and subject to PCAOB inspection. Please disclose any
material risks to the
         company and investors if it is later determined that the PCAOB is
unable to inspect or
         investigate completely your auditor because of a position taken by an
authority in a
         foreign jurisdiction. For example, disclose the risk that lack of
inspection could cause
         trading in your securities to be prohibited under the Holding Foreign
Companies
         Accountable Act and as a result an exchange may determine to delist
your securities.
4.       Please expand your risk factor disclosure to discuss that the United
States Senate passed
         the Accelerating Holding Foreign Companies Accountable Act, which, if
enacted, would
         decrease the number of non-inspection years from three years to two,
thus reducing the
         time period before your securities may be prohibited from trading or
delisted.
        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 Scott Anderegg at 202-551-3342 or Dietrich King at
202-551-8071 with
any questions.



FirstName LastNameTak Ching Poon                                Sincerely,
Comapany NameALE Group Holding Ltd
                                                                Division of
Corporation Finance
November 17, 2021 Page 2                                        Office of Trade
& Services
FirstName LastName