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                            June 2, 2022

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

                                                        Re: Elite Education
Group International Ltd
                                                            Registration
Statement on Form F-3
                                                            Filed May 9, 2022
                                                            File No. 333-264807

       Dear Mr. Wu:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comment. In our comment, 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 comment applies 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 this comment, we may have additional comments.

       Registration Statement on Form F-3 Filed May 9, 2022

       General

   1.                                                   We note your disclosure
in the "Geographic Scope of Our Operations" section on page 2,
                                                        which states that
during the fiscal year ending September 30, 2021, all of your customers
                                                        were Chinese residents.
Please revise your filing, as applicable, to provide more specific
                                                        and prominent
disclosures about the legal and operational risks associated with China-
                                                        based companies. For
additional guidance, please see the Division of Corporation
                                                        Finance   s Sample
Letter to China-Based Companies issued by the Staff in December 2021
                                                        available on our
website at https://www.sec.gov/corpfin/sample-letter-china-based-
                                                        companies.
 Zhenyu Wu
FirstName   LastNameZhenyu   Wu Ltd
Elite Education Group International
Comapany
June  2, 2022NameElite Education Group International Ltd
June 2,
Page  2 2022 Page 2
FirstName LastName
        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.

       Please contact Cara Wirth at (202) 551-7127 or Dietrich King at (202)
551-8071 with any
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services
cc:      Johnathan C. Duncan