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United States securities and exchange commission logo
June 2, 2023
Tsz Him Leung
Chief Executive Officer
Alpha Technology Group Ltd.
Unit B, 12/F, 52 Hung To Road
Kwun Tong, Kowloon, Hong Kong
Re:Alpha Technology Group Ltd.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted May 11, 2023
CIK No. 0001967621
Dear Tsz Him Leung:
            We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form F-1
Business, page 106
1.Your disclosure indicates that “Techlution does not take ownership or control of any
NFTs created in the NFT games, and its access to NFTs is restricted once the games are
delivered to customers and secured on the blockchain.” Please clarify what role the
Company has in the operations of games as it relates to games that enable users to
generate revenue by converting in-game assets into NFTs.  In addition, provide a more
complete description of the reward sharing mechanism and the process by which crypto
assets are rewarded to players, as well as any continued involvement by the company
following customer acceptance.
2.We note your disclosure that you do not "own or hold custody of any of the NFTs that it

 FirstName LastNameTsz Him Leung
 Comapany NameAlpha Technology Group Ltd.
 June 2, 2023 Page 2
 FirstName LastName
Tsz Him Leung
Alpha Technology Group Ltd.
June 2, 2023
Page 2
creates for customers" but that "[d]uring the NFT creation process, customers grant
Techlution access to their private key."  Please revise to discuss whether holding the
private keys for your customers wallets grant you full access to the crypto assets, whether
those assets are held in your custody during the NFT creation and smart-contract
implementation, and whether you have any policies or procedures in place to limit the risk
of theft from your customers' wallets while you hold the private key.  In addition, clarify
whether you continue to hold the private keys after delivery to your customers.
3.We note that your "access to NFTs is restricted once the games are delivered to customers
and secured on the blockchain." Please revise to provide a more complete discussion of
the types of restrictions that are in place following delivery to the customers.  In
addition, clarify whether the Company currently receives, or in the future
intends to receive, any royalties or will derive revenue from the future sales of the NFTs
you create for customers or that are received as in game rewards.
            You may contact Claire DeLabar, Senior Staff Accountant, at (202) 551-3349 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 Marion Graham, Staff
Attorney, at (202) 551-6521 or Matthew Derby, Legal Branch Chief, at (202) 551-3334 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ying Li