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                           April 22, 2022

       Andrew Lee
       Chief Executive Officer
       Global Engine Group Holding Ltd
       Workshop A, 8/F, Reason Group Tower
       403 Castle Peak Road, Kwai Chung
       New Territories, Hong Kong

                                                        Re: Global Engine Group
Holding Ltd
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted on March
25, 2022
                                                            CIK No. 0001908705

       Dear Mr. Lee:

              We have reviewed your draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement submitted March 25, 2022

       Cover Page

   1.                                                   Please revise your
disclosure that you have no clients or suppliers who are in mainland
                                                        China to clarify the
percentage of your revenues generated from Hong Kong. Also, revise
                                                        your disclosure on page
ii to remove the exclusion of Taiwan, Hong Kong and Macau
                                                        from the definition of
the PRC and China.
 Andrew Lee
FirstName   LastNameAndrew
Global Engine   Group HoldingLee
                              Ltd
Comapany
April       NameGlobal Engine Group Holding Ltd
       22, 2022
April 222, 2022 Page 2
Page
FirstName LastName
2.       Please disclose the potential effects of regulation by PRC, including
whether these risks
         could result in a material change in your operations and/or the value
of the securities you
         are registering for sale or could significantly limit or completely
hinder your ability to
         offer or continue to offer securities to investors and cause the value
of such securities to
         significantly decline or be worthless.
Prospectus Summary, page 1

3.       Where you disclose that the audit report included in the prospectus
was prepared by U.S.
         auditors who are currently inspected by the PCAOB, include a
disclosure regarding
         whether your auditor is subject to the determinations announced by the
PCAOB on
         December 16, 2021.
4.       We note your disclosure that you are currently not required to obtain
permission from any
         of the PRC authorities to operate and to issue your shares. Please
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.
5.       Provide a clear description of how cash is transferred through your
organization. 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.
6.       We note that your subsidiaries constitute a material part of your
consolidated financial
         statements. Please provide in tabular form a condensed consolidating
schedule that
         disaggregates the operations and depicts the financial position, cash
flows, and results of
         operations as of the same dates and for the same periods for which
audited consolidated
         financial statements are required. The schedule should present major
line items, such as
         revenue and cost of goods/services, and subtotals and disaggregated
intercompany
         amounts, such as separate line items for intercompany receivables and
investment in
         subsidiary. The schedule should also disaggregate the parent company
and its
         consolidated subsidiaries. Any intercompany amounts should be
presented on a gross
         basis and when necessary, additional disclosure about such amounts
should be included in
         order to make the information presented not misleading.
Risk Factors, page 18

7.       To the extent material, please include a risk factor describing the
potential
         for cybersecurity incidents and data breaches and their potential
impact on your business.
 Andrew Lee
FirstName   LastNameAndrew
Global Engine   Group HoldingLee
                              Ltd
Comapany
April       NameGlobal Engine Group Holding Ltd
       22, 2022
April 322, 2022 Page 3
Page
FirstName LastName
We have a substantial customer concentration..., page 19

8.       We note that for the year ended June 30, 2021, three major customers
accounted for
         57.1%, 18.7% and 17.6%, respectively, of the company   s total
revenues. Please disclose
         the material terms of the agreements with the customers, including the
identity of the
         customers, the term of the agreements and termination provisions. File
the agreements as
         exhibits.
We rely on a limited number of vendors, page 19

9.       You state that four vendors accounted for 32.7%, 21.2%, 20.0% and
14.5%, respectively,
         of the company   s total purchases for the year ended June 30, 2021.
Please disclose the
         material terms of your agreements with the vendors, including the
identity of the vendors,
         term and termination provisions of the agreements, and any minimum
purchase
         commitments. File the agreements as exhibits.
Our business operations have been and may continue to be materially and
adversely affected...,
page 23

10.      You state that you have experienced, and may continue to experience,
disruptions or
         delays in your supply chain as a result of restrictions in response to
COVID-19. Discuss
         the nature of the supply chain issues you have experienced and the
issues that you expect
         to experience. Discuss whether the issues have had or are expected to
have a material
         adverse effect on the company.
Industry, page 63

11.      You state that the Hong Kong telecommunications market mobile
penetration rate is
         291%. Please explain how the mobile penetration rate of Hong Kong can
exceed 100%.
         Disclose the time period in which this rate was measured and discuss
any underlying
         assumptions and limitations of this rate.
Business, page 66

12.      Please disclose whether the four employees you disclosed are employed
by the Global
         Engine Group Holding Limited, Global Engine Holdings Limited, or
Global Engine
         Limited. Further, please clarify for which entity you intend to hire
employees as part of
         your growth strategy.
Management, page 70

13.      Please identify the "company specialising in the supply of lighting
fittings" for which
         Sung Pui Hei is currently the Chief Financial Officer.
 Andrew Lee
FirstName   LastNameAndrew
Global Engine   Group HoldingLee
                              Ltd
Comapany
April       NameGlobal Engine Group Holding Ltd
       22, 2022
April 422, 2022 Page 4
Page
FirstName LastName
Related Party Transactions, page 76

14.      You indicate in the prospectus summary that you have a strategic
partnership with China
         Information Technology Development which also beneficially owns 10% of
the
         company's ordinary shares. Please disclose the material terms of this
related party
         transaction, including any understandings or agreements between the
company and China
         Information Technology Development.
Exhibits

15.      Please tell us whether you intend to file the consent of Sung Pui Hei
who will serve as a
         director and Chief Financial Officer immediately upon the
effectiveness of the registration
         statement. See Rule 438 of Regulation C.
General

16.      Please provide us with supplemental copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         have presented or expect to present to potential investors in reliance
on Section 5(d) of the
         Securities Act, whether or not you retained, or intend to retain,
copies of those
         communications.
       You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or
Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
regarding
comments on the financial statements and related matters. Please contact Lauren
Pierce, Staff
Attorney, at (202) 551-3887 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Technology
cc:      Arila Zhou