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    Simpson
                    Thacher & Bartlett

    icbc
    tower, 35th floor

    3
    garden road, central

    hong
    kong

    telephone:
                    +852-2514-7600

    facsimile:
    +852-2869-7694

    Direct Dial Number

    +852-2514-7660

    E-mail
                                            Address

    dfertig@stblaw.com

March 10, 2023

VIA EDGAR

Division of Corporation Finance

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attention:

Nicholas Nalbantian

Donald Field

 Re: Alibaba Group Holding Ltd

Form
20-F for the Fiscal Year Ended March 31, 2022

Filed July 26, 2022

Response Dated January 11, 2023

File No. 001-36614

Ladies and Gentlemen:

We are submitting this letter in response to your
correspondence dated February 24, 2023 (the “February 24 Letter”) concerning the above-referenced response letter,
dated January 11, 2023, regarding the annual report on Form 20-F that Alibaba Group Holding Limited (the “Company”)
filed with the Securities and Exchange Commission (the “Commission”) on July 26, 2022.

In the February 24 Letter, you requested that
the Company respond to the staff (the “Staff”) of the Commission’s comments within 10 business days or advise
the Staff when the Company will respond. The Company respectfully advises the Staff that it continues to work on its responses and anticipates
that it will require additional time in order to respond fully to your letter.

The Company is therefore requesting an extension
until March 24, 2023 (10 business days from the date of this request) and expects to respond by that date.

*     *     *     *

    michael
    j.c.M. ceulen
    marjory
    j. ding
    daniel
    fertig
    adam
    C. furber
    YI
    GAO
    MAKIKO
    HARUNARI
    Ian
    C. Ho
    JONATHAN
    HWANG
    anthony
    d. king
    jin
    hYUK park
    christopher
    k.s. wong

                                                                                        resident
                                            partners

    simpson
    thacher & bartlett, hong kong is an affiliate of simpson thacher & bartlett llp with offices in:

    New
    York
    Beijing
    Brussels
    Houston
    LONDON
    Los
    Angeles
    Palo
    Alto
    SÃO
    PAULO
    TOKYO
    Washington,
    D.C.

    Simpson Thacher
 & Bartlett

    March
10, 2023

    -2-

If you have any question regarding
the responses contained in this letter, please do not hesitate to contact me at +852-2514-7660 or dfertig@stblaw.com.

    Very truly yours,

    /s/ Daniel Fertig

    Daniel Fertig

  cc:
  Daniel Yong Zhang, Chief Executive Officer

Toby Hong Xu, Chief Financial Officer

Sara Siying Yu, General Counsel

Alibaba Group Holding Limited