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United States securities and exchange commission logo
May 6, 2020
Yimeng Shi
Chief Financial Officer
uCloudlink Group Inc.
Room 2118-2119, 21/F, One Pacific Centre
414 Kwun Tong Road, Kwun Ton
Kowloon, Hong Kong
Re:uCloudlink Group Inc.
Registration Statement on Form F-1
Filed May 4, 2020
File No. 333-237990
Dear Mr. Shi:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, 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 comments apply 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 these comments, we may have additional comments.
Registration Statement on Form F-1
Prospectus Summary
Recent Developments, page 6
1.We note your preliminary estimates of certain results of operations for the three months
ended March 31, 2020, and your statement warning that there are no guarantees that
revenues will grow or remain at similar levels for the rest of 2020.  In light of the
continuing effects of the pandemic well into the second quarter and the likely adverse
impact of the pandemic for the foreseeable future, you should consider expanding your
discussion to discuss the reasonably known likely effects of the pandemic on your results
of operations and financial condition for 2020.

 FirstName LastNameYimeng Shi
 Comapany NameuCloudlink Group Inc.
 May 6, 2020 Page 2
 FirstName LastName
Yimeng Shi
uCloudlink Group Inc.
May 6, 2020
Page 2
Risk Factors
Risks Related to Doing Business in China, page 49
2.We note your risk factor discussion of limitations on the ability of the PCAOB to conduct
investigations of your auditor.  Include an additional risk factor describing the difficulties
in effecting service of legal process, enforcing foreign judgments or bringing actions in
China based on foreign laws.  Highlight recent developments (e.g. Article 177 of PRC
Securities Law effective March 2020) possibly further limiting an overseas regulator from
conducting investigations or from collecting evidence within the PRC.
General
3.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
            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.
            You may contact Charles Eastman, Staff Accountant at (202) 551-3794 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact Michael C.
Foland, Attorney-Advisor, at (202) 551-6711 or Larry Spirgel, Assistant Director, at (202) 551-
3815 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Z. Julie Gao