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                               January 25, 2023

       Howard Lee
       Chief Executive Officer
       Lucas GC Ltd
       Room 5A01, 4th Floor
       Air China Building, Xiaoyun Road
       Sanyuanqiao, Chaoyang District
       Beijing 100027, China

                                                        Re: Lucas GC Ltd
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted January
9, 2023
                                                            CIK No. 0001954694

       Dear Howard Lee:

             We have reviewed your amended 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. Unless we note otherwise, our references to prior comments are
to comments in our
       December 23, 2022 letter.

       Amendment No. 1 to Draft Registration Statement on Form F-1 submitted
January 9, 2023

       Prospectus Summary
       Risk Factors Summary, page 11

   1.                                                   We note your response
to prior comment 2 and that you removed from the cover page the
                                                        statement that you do
not believe there will be material effects on your Hong Kong
                                                        subsidiaries
operations and financial results resulting from the legal and operational risks
                                                        relating to the PRC
regulations. Please remove the statement from this section as well.
 Howard Lee
FirstName  LastNameHoward Lee
Lucas GC Ltd
Comapany
January 25,NameLucas
            2023      GC Ltd
January
Page 2 25, 2023 Page 2
FirstName LastName
Capitalization, page 64

2.       We note your revised disclosures in response to prior comment 12.
Please further revise
         to include a line for mezzanine equity. Also, revise to label the
middle column as "pro
         forma" rather than "pro forma as adjusted."
Business
Our Customers, page 123

3.       We note that in response to prior comment 21, you removed the
cross-reference to risk
         factor disclosure regarding your customer concentration. To the extent
material, please
         provide risk factor disclosure regarding the risks caused by the
concentration among your
         customers. Additionally, please disclose the percentage of your users
who are individuals
         seeking jobs, corporations posting jobs, or talent scouts seeking to
match candidates with
         positions.
Shares Eligible for Future Sale, page 158

4.       Your disclosure that your "ordinary shares have been approved for
listing on the Nasdaq"
         is inconsistent with the disclosure elsewhere that you will apply for
listing on the Nasdaq.
         Please revise or advise.
Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
(k) Revenue recognition, page F-11

5.       We note your revised disclosures in response to prior comment 31.
Please revise to
         disclose the typical payment terms of your arrangements, as well as
any cancellation or
         termination provisions. Refer to ASC 606-10-50-12(b) and (d).
Outsourcing Services, page F-12

6.       We note your response to prior comment 34. Please revise your
disclosures to clarify the
         nature of the work performed in these arrangements, and that you
recognize revenue upon
         project completion, as indicated in your response. Refer to ASC
606-10-50-12(a) and (c).
Permanent employment services, page F-12

7.       Your response to prior comment 32 indicates that the completion of the
probation period
         is the point in time when the PO is deemed satisfied and the customer
accepts transfer of
         control as a proven qualified employee in the long term. Please tell
us how you
         considered the guidance in ASC 606-10-55-85 through 55-88. In this
regard, explain to us
         whether customer acceptance is based on objective or subjective
criteria and include some
         examples of typical customer specifications in your arrangements.
Also, tell us your
         experience with contracts for similar services, whether compliance
with specifications in
         these types of contracts has been demonstrated in the past and how you
considered that in
 Howard Lee
Lucas GC Ltd
January 25, 2023
Page 3
       determining when control transfers. Specifically, tell us how often your
customers have
       determined candidates are not qualified for the job in the long term
during the probation
       period and whether you have replaced candidates.
8.     Please tell us whether you track the number of candidates that do not
pass the probation
       period. If this information is tracked, tell us the number of candidates
placed in the period
       compared to the number that did not pass the probation period. Please
provide this
       information for the year ended December 31, 2021 and for the six months
ended June 30,
       2022.
Item 7. Recent Sales of Unregistered Securities, page II-2

9.     We note your disclosure in the prospectus that you have issued
redeemable preferred
       shares as part of your financing activities. Please disclose the
quantity and holders of your
       preferred shares in this section. Also, disclose the terms of the
preferred shares in the
       Description of Share Capital section.
General

10.    Please update your financial statements in accordance with Item 8.A.4 of
Form 20-F or
       include the representations noted in Instruction 2 thereto as an exhibit
to your registration
       statement.
        You may contact Dave Edgar, Senior Staff Accountant, at (202) 551-3459
or Christine
Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions
regarding comments on
the financial statements and related matters. Please contact Lauren Pierce,
Staff Attorney, at
(202) 551-3887 or Matthew Crispino, Staff Attorney, at (202) 551-3456 with any
other
questions.



                                                              Sincerely,
FirstName LastNameHoward Lee
                                                              Division of
Corporation Finance
Comapany NameLucas GC Ltd
                                                              Office of
Technology
January 25, 2023 Page 3
cc:       Yang Ge
FirstName LastName