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SU Group Holdings Limited

Unit 01 – 03, 3/F, Billion Trade
Centre

31 Hung To Road, Kwun Tong

Kowloon, Hong Kong

Telephone: +852 2341-8183

VIA EDGAR

December 20, 2023

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Taylor Beech

    Donald Field

    Re:
    SU Group Holdings Ltd

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

    Filed December 11, 2023

    CIK No. 0001969863

Dear Ms. Beech:

SU Group Holdings Limited
(the “Company,” “we,” “our” or “us”) hereby transmits our
response to the comment letter received from the staff (the “Staff”, “you” or “your”)
of the U.S. Securities and Exchange Commission (the “Commission”), dated December 14, 2023, regarding the Amendment
No. 1 to Registration Statement on Form F-1 (the “Registration Statement”) filed with the Commission on December 11,
2023.

For the Staff’s convenience,
we have repeated below the Staff’s comment in bold, and have followed the comment with the Company’s response. Disclosure
changes made in response to the Staff’s comment have been made in Amendment No. 2 (“Amendment No. 2”) to the
Registration Statement on Form F-1, which is being filed with the Commission contemporaneously with the submission of this letter.

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

Prospectus Summary

Recent Developments, page 13

 1. Please balance your preliminary revenue and metrics figures
by including disclosures that:

 ● put the preliminary figures into context,

 ● provide information as to your costs and expenses and

 ● discuss whether trends in revenues and costs and expenses during the recent period

 ● are consistent with those discussed in management’s discussion and analysis.

Also, please remove your statement that
your final results may differ materially from the estimates you are presenting, as it implies that investors should not rely on the
information presented.

Response to Comment No. 1: In
response to the Staff’s comment, we have revised our disclosure in the Prospectus Summary on page 13 of Amendment No. 2 to the
Registration Statement.

We thank the Staff in advance
for its consideration of the foregoing. Should you have any questions, please do not hesitate to contact our legal counsel, Richard I.
Anslow, Esq., of Ellenoff Grossman & Schole LLP, at (212) 370-1300.

    Sincerely,

    By:
    /s/ Dave Chan Ming

    Name:
    Dave Chan Ming

    Title:
    Chief Executive Officer

    cc:
    Ellenoff Grossman & Schole LLP