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                              January 3, 2022

       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. 5 to Registration Statement on Form F-1
                                                            Filed November 22,
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. 5 to Registration Statement on Form F-1
filed November 22,
       2021

       Summary of Risk Factors, page 1

   1.                                                   Please revise to
provide here a cross-reference to the applicable page in your risk factor
                                                        disclosure for each
risk factor listed.
       Recent Regulatory Development in PRC, page 6

   2.                                                   We note your response
to comment 2. Please provide on your cover page a brief
                                                        description of 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
January 3, 2022
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 your response to our comment 4. Please revise to acknowledge
that the SEC
         recently adopted amendments to finalize rules implementing the
submission and
         disclosure requirements in the Holding Foreign Companies Accountable
Act, summarize
         the content of those rules and how they could impact you.
        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 202-551-8071 or Dietrich King at
202-551-8071 with
any question.



FirstName LastNameTak Ching Poon                                Sincerely,
Comapany NameALE Group Holding Ltd
                                                                Division of
Corporation Finance
January 3, 2022 Page 2                                          Office of Trade
& Services
FirstName LastName