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CORRESP
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    Mason
    Allen

    Of
    Counsel

    mallen@cronelawgroup.com

VIA
EDGAR

March
27, 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. 3 to Registration Statement on Form F-1

    Filed
    March 14, 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 22, 2023, commenting on the Company’s Amendment No. 3 to the
Registration Statement on Form F-1 filed March 14, 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. 3 to Registration Statement on Form F-1 filed March 14, 2023

Regulatory
Permission, page 7

Cover
Page

    1.
    We
    note your response comment 1 and reissue in part. In addition to your removal from this section of disclosure discussing the “Draft
    Overseas Listing Regulations,” please also add disclosure disclosing the “Trial Administrative Measures of Overseas Securities
    Offering and Listing by Domestic Enterprises” as you have done on page 65 of the registration statement.

Response:
In response to this comment, the Company has amended the Registration Statement cover page to replicate the Trial Administrative Measures
of Overseas Securities Offering and Listing by Domestic Enterprises disclosure from page 65 of the Registration Statement.

Consolidated
Financial Statements, page F-1

    2.
    Please
    either file as an exhibit the representation discussed in Instruction 2 to Item 8.A.4 of Form 20-F or include audited financial statements
    for the year ended December 31, 2022, as applicable.

Response:
In response to this comment, the Company has amended the Registration Statement to file as an exhibit the request for waiver and representation
under Item 8.A.4 of Form 20-F.

General

    3.
    We
    note your response to comment 4 and your revised disclosures. Please further revise your disclosure to reflect that the selling security
    holders will offer and sell their ordinary shares at either a fixed price or within a specified range until such time as the ordinary
    shares are quoted on the OTCQB marketplace, and thereafter at prevailing market prices. Please be sure to disclose the fixed price
    or a bona fide price range in a pre-effective amendment (i.e., specify the dollar amount of the fixed price or the dollar amounts
    of the price range). Finally, please include the revised pricing disclosure on the prospectus cover page and in the prospectus summary,
    selling security holder and plan of distribution sections of the prospectus.

Response:
In response to this comment, the Company has amended the Registration Statement to clarify, in the prospectus cover page, the prospectus
summary, selling security holder and plan of distribution, that the Selling Stockholders will sell
the shares through public or private transactions at a purchase price of $0.20 per share until the shares are eligible for proprietary
quotations and quoted on the OTCQB Markets, and thereafter at prevailing market prices or at privately negotiated prices.

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.