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CORRESP
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filename1.htm

ALE
Group Holding Limited

Unit
1005, 10/F, Tower A, New Mandarin Plaza,

14
Science Museum Road, Tsim Sha Tsui, Hong Kong

May
27, 2022

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade and Services

100
F Street, N.E.

Mail
Stop 3561

Washington,
DC 20549

Attn:
Scott Anderegg

    Re:
    ALE
    Group Holding Ltd.

        Post-Effective Amendment No. 8 to Registration Statement on Form F-1

    Filed
    May 6, 2022

    File
    No. 333-239225

Dear
Mr. Anderegg:

ALE
Group Holding Limited (the “Company”, “ALE,” “we”, “us” or
“our”) hereby transmits its response to the letter received from the staff (the “Staff”) of the
Securities and Exchange Commission (the “Commission”), dated May 26, 2022 regarding our post-effective amendment No.8
to registration statement on F-1 (the “Registration Statement”). For ease of reference, we have repeated the Commission’s
comments in this response and numbered them accordingly. The post-effective amendment No.9 to the Registration Statement accompanying
this Response Letter is referred to as the Amended Registration Statement.

Post-Effective
Amendment No. 8 to Registration Statement on Form F-1 filed May 6, 2022

Cover
Page

    1.
    We
    note your response to comment 1, as well as your revised disclosure, which focuses on the potential adverse consequences only if
    you added a variable interest entity to your corporate structure. Please revise this disclosure to encompass your corporate structure
    generally. The revised disclosure should address that if changes to the arrangements between the PRC and Hong Kong and the PRC’s
    expanded authority in Hong Kong result in PRC regulatory authorities disallowing your current structure, it would likely result
    in a material change in your operations and/or a material change in the value of your securities.

Response:
In response to the Staff’s comment, we have revised the disclosure on the cover page accordingly.

Summary
of Risk Factors, page 1

    2.
    We
    note your response to comment 5. For each risk factor listed here, please provide a cross reference to the specific page that the
    risk factor starts on in your filing. A general reference to the page number of the beginning of the risk factors section is not
    sufficient for this purpose.

Response:
In response to the Staff’s comment, we have revised to provide cross references to the specific page that each risk factor starts
on pages 1, 2, and 3 accordingly.

General

    3.
    Please
    file as a consent from the Han Kun Law Offices to being named as an expert in the registration statement. In this regard, we note
    the law firm's opinion filed as Exhibit 8.3 does not contain such consent language, notwithstanding the note in the exhibit index
    for Exhibit 99.11 indicating that the consent is included in Exhibit 8.3.

Response:
In response to the Staff’s comment, we have filed an updated opinion issued by Han Kun Law Offices as Exhibit 8.3, which included
Han Kun Law Offices’ consent.

We
thank the Staff for its review of the foregoing. If you have further comments, we ask that you forward them by electronic mail to our
counsel, Joan Wu at jwu@htflawyers.com or by telephone at (212) 530-2208 or Ying Li at yli@htflawyers.com or by telephone at (212) 530-2206.

    Very truly yours,

    /s/ Tak Ching
    (Anthony) Poon

    Tak Ching (Anthony) Poon

    Chief Executive Officer

    cc:
    Joan
    Wu, Esq.

    Ying
    Li, Esq.

    Hunter Taubman Fischer & Li LLC