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                               December 9, 2020

       Anthony Poon
       Chief Executive Officer
       ALE Group Holding Ltd
       Unit 1005, 10/F, Tower A, New Mandarin Plaza,
       14 Science Museum Road,
       Tsim Sha Tsui, Hong Kong

                                                        Re: ALE Group Holding
Ltd
                                                            Registration
Statement on Form F-1
                                                            Response Dated
December 2, 2020
                                                            File No. 333-239225

       Dear Mr. Poon:

              We have reviewed your 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 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.

       Registration Statement on Form F-1

       Exhibit 23.1, page 1

   1.                                                   Please note that, prior
to effectiveness, you will need to file an updated auditor consent.
               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.

              Refer to Rules 460 and 461 regarding requests for acceleration.
Please allow adequate
       time for us to review any amendment prior to the requested effective
date of the registration
       statement.
 Anthony Poon
ALE Group Holding Ltd
December 9, 2020
Page 2

       You may contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at
202-551-
3307 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,
FirstName LastNameAnthony Poon
                                                         Division of
Corporation Finance
Comapany NameALE Group Holding Ltd
                                                         Office of Trade &
Services
December 9, 2020 Page 2
cc:       Joan Wu
FirstName LastName