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CHEN-DRAKE LAW

8491 Sunset Blvd., Suite 368

W. Hollywood, CA 90069

(310) 358-0104 (t); 888-896-7763 (f)

March 16, 2020

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549-6010

    Attention:

        Wilson K. Lee, Senior Staff Accountant

        Peter McPhun, Staff Accountant

    Re:

        Prime Global Capital Group Incorporated

        Form 10-K for the Fiscal Year ended October 31, 2019 (the “2019
        Form 10-K)

        Filed February 3, 2020

        File No. 000-54288

Ladies and Gentlemen:

On behalf
of Prime Global Capital Group Incorporated (the “Company” or “PGCG”), we are
hereby responding to the comment letter dated March 11, 2020 (the “Staff Letter”), from the staff of
the Securities and Exchange Commission (the “Staff”) relating to the Company’s response to the
Staff comment letter dated March 5, 2020. For ease of review, we have set forth each of the Staff’s comments in accordance
with the numbering presented in the Staff Letter and the Company’s responses thereto.

Form 10-K for the Fiscal Year Ended October
31, 2019

Report Of Independent Registered Public
Accounting Firm, page F-1

1. We
note your response to our prior comment number two. However, the revised audit opinion included as Exhibit A does not address internal
control over financial reporting as required by paragraphs 59 and 60 of PCAOB Auditing Standard 3105. Please request a revised
audit opinion from your independent registered public accounting firm that contains the required language concerning internal control
over financial reporting and revise your filing to include such conforming audit opinion.

Response:
We will amend the 2019 Form 10-K to include the revised audit opinion attached hereto as Exhibit A.

Wilson K. Lee

Peter McPhun

Securities and Exchange Commission

March 16, 2020

Page 2

In providing the foregoing answers, the
Company acknowledges that:

 · It is responsible for the adequacy and accuracy of the disclosure in the filing;

 · Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission
from taking any action with respect to the filing; and

 · The company may not assert staff comments as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

We hope
the foregoing answers are responsive to your comments. Please do not hesitate to contact me by telephone at (310) 358-0104,
or by fax at (888) 896-7763 with any questions or comments regarding this correspondence.

Very truly yours,

/s/   Jenny Chen-Drake

Jenny Chen-Drake

of CHEN-DRAKE LAW

        cc:

        Prime Global Capital Group Incorporated (via email)

Wilson K. Lee

Peter McPhun

Securities and Exchange Commission

March 16, 2020

Page 3

EXHIBIT A

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING
FIRM

To the Shareholders and the Board of Directors
of Prime Global Capital Group Incorporated

Opinion on the Financial Statements

We have audited the accompanying consolidated
balance sheets of Prime Global Capital Group Incorporated and its subsidiaries (the “Company”) as of October 31, 2019
and 2018, the related consolidated statements of operations and comprehensive loss, changes in stockholders' equity and cash flows
for each of the two years in the period ended October 31, 2019, and the related notes and schedules (collectively referred to as
the “financial statements”).

In our opinion, the financial statements present
fairly, in all material respects, the financial position of the Company as of October 31, 2019 and 2018, and the results of its
operations and its cash flows for each of the two years in the period ended October 31, 2019, in conformity with accounting principles
generally accepted in the United States of America.

Going concern

The accompanying financial statements have been
prepared assuming that the Company will continue as a going concern. As discussed in Note 2 to the financial statements, the Company
reported a net loss of $268,058, a net current asset deficiency with its current liabilities exceeding its current assets by $1,467,703,
an accumulated deficit of $4,545,195 as of October 31, 2019 from recurring net losses, and significant short term debt maturing
in less than one year. All these factors raise substantial doubt about its ability to continue as a going concern.

Management's plans in regard to these matters
are also discussed in Note 2 to the financial statements. The financial statements do not include any adjustments that might result
from the outcome of this uncertainty.

Basis for Opinion

These financial statements are the responsibility
of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audits.
We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB")
and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable
rules and regulations of the Securities and Exchange Commission and the PCAOB.

Wilson K. Lee

Peter McPhun

Securities and Exchange Commission

March 16, 2020

Page 4

We conducted our audits in accordance with the
standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether
the financial statements are free of material misstatement, whether due to error or fraud. The Company is not required to have,
nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audits we are required
to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the
effectiveness of the Company's internal control over financial reporting. Accordingly, we express no such opinion.

Our audits included performing procedures to
assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures
that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures
in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made
by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a
reasonable basis for our opinion.

ShineWing Australia

Chartered Accountants

We have served as the Company’s auditor
since 2017.

Melbourne, Australia

January 31, 2020