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UCLOUDLINK GROUP INC.

Unit 2214-Rm1, 22/F, Mira Place Tower A

132 Nathan Road, Tsim Sha Tsui

Kowloon, Hong Kong

October 7, 2022

    VIA EDGAR

    Mr. Joseph Cascarano, Senior Staff Accountant

    Mr. Robert S. Littlepage, Accountant Branch Chief

    Division of Corporation Finance

    Office of Technology

    U.S. Securities and Exchange Commission

    100 F Street, NE

    Washington, D.C. 20549

 Re: UCLOUDLINK
                                            GROUP INC. (the “Company”)

Form 20-F
for the Fiscal Year Ended December 31, 2021

Filed
April 27, 2022

File
No. 001-39302

Dear Mr. Cascarano and Mr. Littlepage:

This letter sets forth the Company’s responses
to the comments contained in the letter dated September 8, 2022 from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) regarding the Company’s Form 20-F for the fiscal year ended December 31, 2021 filed with
the Commission on April 27, 2022 (the “2021 Form 20-F”). The Staff’s comments are repeated below in bold and are followed
by the Company’s responses thereto. All capitalized terms used but not defined in this letter shall have the meaning ascribed to
such terms in the 2021 Form 20-F.

FORM 20-F FOR THE FISCAL YEAR
ENDED DECEMBER 31, 2021

Note 19. Other Investments, page
F-39

1. You disclose a significant amount of current and long-term Other Investments that include investments in debt
and equity securities. Please revise to provide, and tell us your consideration of, the information required by ASC 320-10-50,
ASC 321-10-50 and ASC820-10-50, as applicable, including the classification information required by major security type
and fair value measurement methodology and levels used to value these investments.  Revise your discussion of liquidity
and capital resources on page 101 to expand and clarify the disclosure of these products comprising your Other investments.

Securities and Exchange Commission

October 7, 2022

Page 2

The Company respectfully advises the Staff that the Other
Investments held by the Company as of December 31, 2021 represented two separate investments:

 (i) A current investment in an investment fund representing ownership interest in an entity, for which the underlying assets were comprised
of debt and equity securities. The investment by the Company in this investment fund itself has been classified as an equity security
in accordance with ASC 321-10-20; and

 (ii) A non-current investment in an investment product which has been classified as a debt security carried at fair value in accordance
with ASC 320-10-20.

Both the equity and debt securities were measured and recorded
at fair value on a recurring basis with changes in fair value, whether realized or unrealized, recorded through the consolidated statements
of comprehensive income/(loss). The fair value was determined based on quoted prices from the investment fund or asset management company,
which were the executable transaction prices and the amounts that redemption and new purchases can be made, using level 2 inputs (ASC
820-10-35).

The nature and the measurement of these two investments had
been disclosed in note 2.29 and note 19 to the consolidated financial statements of the Company. In response to the Staff’s comment,
the Company respectfully proposes to revise and include the following underlined disclosure regarding the classification information,
fair value measurement methodology and levels used to value these investments in note 19 to its financial statements in its future Form
20-F filings, subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed:

“19. Other investments

    (In thousands)
    December 31, 2020
    December 31, 2021

    Current(i)
      19,185
      12,587

    Non-current(ii)
      17,824
      12,058

    Total
      37,009
      24,645

Notes:

 (i) In June 2020, the Group made an investment in an investment fund, which was classified as an equity security, for a cash consideration
of US$15,000 thousands, for which the underlying assets were mainly comprised of debt securities and equity securities. It is redeemable
at the option of the Group with one-month notice. The equity security was measured and recorded at fair value on a recurring
basis based on the quoted price by the investment fund which was the executable transaction prices and the amounts that redemption and
new purchases can be made and classified as level 2 inputs. There was a fair value gain of US$4,185 thousands for the year ended
December 31, 2020 and a fair value loss of US$6,598 thousands for the year ended December 31, 2021.

Securities and Exchange Commission

October 7, 2022

Page 3

 (ii) In June 2020, the Group made an investment, which was classified as a debt security carried at fair value, for a cash consideration
of US$17,100 thousands, for which the underlying assets were mainly comprised of unlisted bonds and subordinated debentures, for
a period of 3 years. The debt security was measured and recorded at fair value on a recurring basis based on the quoted price
by the asset management company, which was the executable transaction prices and the amounts that redemption and new purchases can be
made and classified as level 2 inputs. There was a fair value gain of US$724 thousands for the year ended December 31,2020 and
a fair value loss of US$5,766 thousands for the year ended December 31, 2021. “

The Company also respectfully proposes to add the following
disclosure in the discussion of liquidity and capital resources in its future Form 20-F filings, subject to updates and adjustments to
be made in connection with any material development of the subject matter being disclosed:

“As of December 31, 2020 and 2021, we had US$37.0 million
and US$24.6 million other investments, respectively. Other investments included
the followings.

 ● In
                                            June 2020, we made an investment in an investment fund representing ownership interest in
                                            an entity, for which the underlying assets were comprised of debt and equity securities for
                                            a cash consideration of US$15 million. We classify this current investment as an equity security,
                                            measured and recorded at fair value on a recurring basis based on the quoted transaction
                                            price by the investment fund. The fair value of this investment was US$19.2 million and US$12.6
                                            million as of December 31, 2020 and 2021, respectively.

 ● In June 2020, we made an investment in an investment product for which the underlying assets were mainly comprised of unlisted bonds
and subordinated debentures for a cash consideration of US$17 million with a period of three years. We classify this non-current investment
as a debt security, measured and recorded at fair value on a recurring basis based on the quoted transaction price by the asset management
company. The fair value of this investment was US$17.8 million and US$12.1 million as of December 31, 2020 and 2021, respectively.”

*	*	*

    Very truly yours,

    /s/ Yimeng Shi

    Yimeng Shi

    Chief Financial Officer

Enclosures.

 cc: Chaohui Chen, Chief Executive Officer, UCLOUDLINK GROUP INC.

Zhiping Peng, Chairman of the Board of
Directors, UCLOUDLINK GROUP INC.

Shu Du, Esq., Partner, Skadden, Arps, Slate,
Meagher & Flom LLP