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                             December 23, 2021

       Sze Hon, Johnson Chen
       Chief Executive Officer
       Magic Empire Global Limited
       3/F, 8 Wyndham Street
       Central, Hong Kong

                                                        Re: Magic Empire Global
Limited
                                                            Amendment No. 2 to
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted November
12, 2021
                                                            CIK No. 0001881472

       Dear Mr. Chen:

             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.

       Draft Registration Statement submitted November 12, 2021

       Cover page

   1.                                                   Please disclose here
whether your auditor is subject to the determinations announced by
                                                        the PCAOB on December
16, 2021 and whether and how the Holding Foreign Companies
                                                        Accountable Act and
related regulations will affect your company.
   2.                                                   Please refer to comment
4 in our letter dated September 30, 2021. Please disclose here
                                                        whether you need to
obtain any government approvals to operate in Hong Kong or offer
                                                        the securities. Please
also describe the consequences to you and your investors if you or
                                                        your subsidiaries: (i)
do not receive or maintain such permissions or approvals, (ii)
 Sze Hon, Johnson Chen
Magic Empire Global Limited
December 23, 2021
Page 2
       inadvertently conclude that such permissions or approvals are not
required, or (iii)
       applicable laws, regulations, or interpretations change and you are
required to obtain such
       permissions or approvals in the future.
3.     Please refer to comment 5 in our letter dated September 30, 2021. Please
describe here
       how cash is transferred through your organization and disclose your
intentions to
       distribute earnings. State whether any transfers, dividends, or
distributions have been
       made to date between the holding company, its subsidiaries, or to
investors, and quantify
       the amounts where applicable. Provide cross-references to the condensed
consolidating
       schedule and the consolidated financial statements. We note in this
regard your disclosure
       on pages 3-4.
        You may contact Rolf Sundwall at (202) 551-3105 or Mark Brunhofer at
(202) 551- 3638
if you have questions regarding the financial statements and related matters.
Please contact Eric
Envall at (202) 551-3234 or J. Nolan McWilliams at (202) 551-3217 with any
other questions.



                                                            Sincerely,
FirstName LastNameSze Hon, Johnson Chen
                                                            Division of
Corporation Finance
Comapany NameMagic Empire Global Limited
                                                            Office of Finance
December 23, 2021 Page 2
cc:       Lawrence S. Venick, Esq.
FirstName LastName