SecProbe.io

CORRESP
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Mason
                                            Allen

                                                                                Of Counsel

                                                                                mallen@cronelawgroup.com

VIA
EDGAR

March
14, 2023

THE
UNITED STATES SECURITIES

AND
EXCHANGE COMMISSION

Washington,
D.C. 20549

    Attn:
    Rucha
    Pandit

    Donald
    Field

    Aamira
    Chaudhry

    Rufus
    Decker

    Re:
    Qilun
    Group Inc.

    Amendment
    No. 2 to Registration Statement on Form F-1

    Filed
    February 27, 2023

    File
    No. 333-268512

Dear
Ms. Pandit, Mr. Field, Ms. Chaudhry and Mr. Decker:

We
write on behalf of Qilun Group Inc. (the “Company”) in response to comments by the United States Securities and Exchange
Commission (the “Commission”) in its letter dated March 9, 2023, commenting on the Company’s Amendment No. 2 to the
Registration Statement on Form F-1 filed February 27, 2023 (the “Registration Statement”).

Titling
and paragraph numbering of the comments listed below corresponds to the titling and numbering used in the Commission’s comment
letter.

Amendment
No. 2 to Registration Statement on Form F-1

Cover
Page

1. We
                                            note that there have been a number of developments related to the China Securities Regulatory
                                            Commission and its related statutes and regulations, in particular the February 17, 2023
                                            Trial Administrative Measures of Overseas Securities Offering and Listing by Domestic Enterprises
                                            and the five application guidelines, which will take effect on March 31, 2023. Please revise
                                            the prospectus cover page and prospectus throughout based on the most up to date information.

Response:
In response to this comment, the Company has amended the Registration Statement cover page and related sections to reflect the most up-to-date
information regarding the China Securities Regulatory Commission and its related statutes and regulations.

2. We
                                            note your response to comment 4 and reissue in part. We note your disclosure here and in
                                            The Offering section on page 8 that you intend to seek a quotation on the OTCQB. We also
                                            note references throughout the prospectus to a Nasdaq listing. Please delete all such references
                                            as you do not appear to be seeking a Nasdaq listing and revise the prospectus throughout
                                            accordingly.

Response:
In response to this comment, the Company has amended the Registration Statement to omit references to the Nasdaq Stock Market, which
were included in our previous filing in error.

Cooperation
Agreement on Sales Commissions, page 69

3. We
                                            note your response to comment 6 and reissue in part. Please disclose clearly whether the
                                            Cooperation Agreement has been renewed.

Response:
In response to this comment, the Company has amended the Registration Statement to clarify that the Cooperation Agreement has been renewed
as of the date of the Registration Statement.

Plan
of Distribution, page 82

4. We
                                            note your response to comment 5 and reissue in part. We acknowledge the changes you have
                                            made on the prospectus cover page to the registration statement, but the Plan of Distribution
                                            still contains the previous inconsistent description of the offering terms. Please clarify
                                            this discrepancy.

Response:
In response to this comment, the Company has amended the Registration Statement prospectus cover and under the caption, “Plan
of Distribution” to clarify that the Company is registering the offer and resale of an aggregate of 16,550,000 Ordinary Shares,
$0.0001 par value per share, on behalf of the Selling Stockholders; that there is currently no public trading market for the Ordinary
Shares; there is no public market for our securities; our securities are not currently
eligible for trading on any national securities exchange or any over-the-counter markets, including OTC Markets; that we intend to have
our ordinary shares eligible for proprietary quotations and quoted on the OTCQB marketplace of OTC Markets, Inc. (“OTC Markets”)
following the effectiveness of the registration statement; that to become eligible for proprietary quotations on OTC Markets, we require
the assistance of a FINRA registered broker that will act as a market maker and submit the application on our behalf to FINRA.

Item
8. Exhibits and Financial Schedules

(a)
Exhibits

Exhibit
23.1, page II-1

5. We
                                            note your response to our prior comment 8. The audit report is dated November 22, 2022. The
                                            consent refers to an audit report dated February 24, 2023. Please advise and revise accordingly.

Response:
In response to this comment, the Company has amended the Registration Statement exhibit 23.1, the Consent of Assentsure PAC, to refer
to the audit report dated November 22, 2022.

Please
feel free to contact me should you require additional information at (917) 574-7812 or mallen@cronelawgroup.com.

THE
CRONE LAW GROUP, P.C.

    By:
    /s/
    Mason Allen

    Mason
    Allen, Esq.