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                          October 19, 2020

       Zhenyu Wu
       Chief Financial Officer
       Elite Education Group International Ltd
       1209 N. University Blvd.
       Middletown, OH 45042

                                                        Re: Elite Education
Group International Ltd
                                                            Amendment No. 6 to
Draft Registration Statement on Form F-1
                                                            Submitted October
13, 2020
                                                            CIK 0001781397

       Dear Mr. Wu:

             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.

       Amendment No. 6 to Draft Registration Statement on Form F-1

       Use of Proceeds, page 30

   1.                                                   We note your response
to our prior comment 1. In your next amendment, please update
                                                        this section to reflect
your response.
 Zhenyu Wu
FirstName  LastNameZhenyu    Wu Ltd
Elite Education Group International
Comapany
October 19,NameElite
            2020     Education Group International Ltd
October
Page  2 19, 2020 Page 2
FirstName LastName
Properties, page 49

2.       We note your response to our prior comment 4. We also note that the
Renda Agreement
         originally contemplated the payment of RMB 2.9 million for rent
expense as well as other
         services including hiring, administration, and paying employees.
Please disclose whether
         the new rental expense of $1.0 million includes such other services
and whether there
         have been changes in payment or fees with respect to such other
services. If there has
         been a material amendment to the Renda Agreement, please include it as
an exhibit.
       You may contact Tony Watson at (202) 551-3318 or Doug Jones at (202)
551-3309 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Cara Wirth at (202) 551-7127 or Lilyanna Peyser at (202) 551-3222 with
any other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services
cc:      F. Alec Orudjev, Esq.