February 11, 2020

Eldee Tang
Chief Executive Officer
Noble Vici Group, Inc.
1 Raffles Place #33-02
One Raffles Place Tower One
Singapore 048616

       Re: Noble Vici Group, Inc.
           Form 10-K for Fiscal Year Ended March 31, 2019
           Filed July 15, 2019
           File No. 000-54761

Dear Mr. Tang:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for Fiscal Year Ended March 31, 2019

Key Performance Indicators: Gross Cash Receipts, Supplier Product & Logistics
Allowance and
Commission Payout, page 17

1.    Please tell us how the items under this heading correlates to your
financial statements. In
      this regard, we note you reconcile gross cash receipts to net sales yet
it is unclear why the
      reconciling items are excluded from gross cash receipts and not included
in your financial
      statements. For example, if you received cash proceeds for undelivered
items, we would
      anticipate this amount to be recorded as deferred revenue. However, we
are unable to
      reconcile this amount to the change in deferred revenue on your balance
sheet. Please
      advise how you are accounting for undelivered items. Further, it is
unclear why supplier's
      product and logistics allowances and commission payout are excluded from
net sales
      rather than being presented gross. Please explain how you accounted for
such items based
      on your stated revenue recognition policies on page F-10 and revise your
discussion to
 Eldee Tang
Noble Vici Group, Inc.
February 11, 2020
Page 2
         indicate why management believes the presentation provides useful
information to
         investors.
Report of Independent Registered Public Accounting Firm, page F-2

2.       We note the existence of "Emphasis of Matter" language in the report
of your independent
         registered public accounting firm. Such language makes reference to
Note 2 where
         management expresses substantial doubt about the Company's ability to
continue as a
         going concern. Please note that AS 2415.03c of the PCAOB's general
auditing
         standards requires the auditor to include an explanatory paragraph,
including an
         appropriate title (immediately following the opinion paragraph), in
his audit report to
         reflect his conclusion if substantial doubt exists. Please have your
auditor's review the
         appropriate audit standards and revise their opinion, if necessary, to
be in conformity
         therewith. If your auditor believes no revision is necessary, please
explain in detail.
       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.

      You may contact Patrick Kuhn at (202) 551-3308 or Jim Allegretto at (202)
551-
3849 with any questions.



FirstName LastNameEldee Tang                                 Sincerely,
Comapany NameNoble Vici Group, Inc.
                                                             Division of
Corporation Finance
February 11, 2020 Page 2                                     Office of Trade &
Services
FirstName LastName