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                           January 26, 2022

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

                                                        Re: ALE Group Holding
Ltd
                                                            Post-Effective
Amendment No. 6 to Registration Statement on Form F-1
                                                            Filed January 10,
2022
                                                            File No. 333-239225

       Dear Mr. Poon:

              We have reviewed your post-effective amendment 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.

       Post-Effective Amendment No. 6 to Registration Statement on Form F-1
filed on January 10,
       2022

       Cover Page

   1.                                                   Please disclose on the
prospectus cover page 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. Your
prospectus summary should also address, but not necessarily be limited to,
                                                        the risks highlighted
on the prospectus cover page.
 Tak Ching Poon
FirstName
ALE GroupLastNameTak
            Holding Ltd Ching Poon
Comapany
January 26,NameALE
           2022      Group Holding Ltd
January
Page 2 26, 2022 Page 2
FirstName LastName
Prospectus Summary
Summary of Risk Factors, page 1

2.       We note your response to comment 1 and your revised disclosure. For
each risk factor
         listed here, please provide a cross reference to the specific page
that the risk factor starts
         on in your filing. A general reference to the page number of the
beginning of the risk
         factors section is not sufficient for this purpose.
Risks Related to Our Ordinary Shares and This Offering, page 3

3.       Disclose that trading in your securities may be prohibited under the
Holding Foreign
         Companies Accountable Act if the PCAOB determines that it cannot
inspect or investigate
         completely your auditor, and that as a result an exchange may
determine to delist your
         securities. Disclose whether your auditor is subject to the
determinations announced by
         the PCAOB on December 16, 2021.
        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 Scott Anderegg at 202-551-3342 or Dietrich King at
202-551-8071 with
any questions.



                                                                 Sincerely,

                                                                 Division of
Corporation Finance
                                                                 Office of
Trade & Services