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April 27, 2020
Eldee Tang
Chief Executive Officer
Noble Vici Group, Inc.
1 Raffles Place #33-02
One Raffles Place Tower One
Singapore 048616
Re:Noble Vici Group, Inc.
Form 10-K for Fiscal Year Ended March 31, 2019
Filed July 15, 2019
File No. 000-54761
Response dated April 14, 2020
Dear Mr. Tang:
            We have reviewed your April 14, 2020 response to our comment letter and have the
following comment.  In our comment, we ask you to provide us with information so we may
better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
March 19, 2020 letter.
Form 10-K for Fiscal Year Ended March 31, 2019
Key Performance Indicators: Gross Cash Receipts, Supplier Product & Logistics Allowance and
Commission Payout, page 17
1.We note your response to our prior comment 1 and your proposal to remove the
discussions on non-GAAP measurements and replace the measures with the following
three metrics to gauge your performance: (1) Gross Merchandise Value (GMV);
(2) Maximum Purchasing Performance (MPP); and SMGA Costs. Please tell us and
disclose in greater detail how the MPP and the SMGA metrics provide useful information
to investors. In this regard, we note that MPP is calculated by dividing cost of goods sold
by GMV wherein cost of goods sold is an actual cost number recorded on your financial

 FirstName LastNameEldee Tang
 Comapany NameNoble Vici Group, Inc.
 April 27, 2020 Page 2
 FirstName LastName
Eldee Tang
Noble Vici Group, Inc.
April 27, 2020
Page 2
statements while GMV represents the aggregate of suggested retail prices of goods
offered, as opposed to sold, on your website and does not represent actual amounts of
sales or GMV that were realized through sales. In addition, it appears to us that the same
holds true of SGMA ratio in that it is calculated from a suggested value instead of a
realized value. Please make any necessary modifications and revise your presentation.
            You may contact Patrick Kuhn at (202) 551-3308 or Jim Allegretto at (202) 551-3849 if
you have any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services