United States securities and exchange commission logo 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