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Acceleration Request

 Alibaba Group Holding Limited

c/o Alibaba Group Services Limited

26/F Tower One, Times Square

 1
Matheson Street

 Causeway Bay

Hong Kong

 September 16, 2014

 VIA EDGAR

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Attention:

Ms. Mara L. Ransom, Assistant Director

Mr. Dietrich King, Legal Branch Chief

Ms. Lisa Kohl, Senior Attorney

Re:

        Alibaba Group Holding Limited

        Registration Statement on Form F-1, as amended (File No. 333-195736)

        Registration Statement on Form 8-A (Registration No. 001-36614)

 Ladies and Gentlemen:

Pursuant to Rule 461 of Regulation C (“Rule 461”) promulgated under the Securities Act of 1933, as amended, Alibaba Group Holding
Limited (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1 (the “F-1 Registration Statement”) be accelerated to, and that the Registration Statement become effective
at, 4:00 P.M., Eastern Daylight Time on September 18, 2014, or as soon thereafter as practicable.

 The Company also requests that the
Registration Statement on Form 8-A, as amended, under the Securities Exchange Act of 1933, as amended, covering the American depositary shares representing ordinary shares of the Company (the “Registration Statement on Form 8-A,” together
with the F-1 Registration Statement, the “Registration Statements”), be declared effective immediately following the F-1 Registration Statement.

If there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the
Company may be making an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461. Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S.
counsel, Simpson Thacher & Bartlett LLP.

 The Company understands that Credit Suisse Securities (USA) LLC, Deutsche Bank
Securities Inc., Goldman Sachs (Asia) L.L.C., J.P. Morgan Securities LLC, Morgan Stanley & Co. International plc and Citigroup Global Markets Inc., on behalf of the prospective underwriters of the offering, have joined in this request in a
separate letter delivered to you today.

 The Company hereby acknowledges the following:

•

should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and

•

the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 [Signature page follows]

Very truly yours,

Alibaba Group Holding Limited

By:

 /s/ Timothy A. Steinert

Name: Timothy A. Steinert

Title:   General Counsel and Corporate Secretary