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 February 27, 2026

Wing Fung Alfred Siu
Chief Executive Officer
NewGenIvf Group Ltd
36/39-36/40, 13th Floor, PS Tower
Sukhumvit 21 Road (Asoke)
Khlong Toei Nuea Sub-district
Watthana District, Bangkok 10110
Thailand

 Re: NewGenIvf Group Ltd
 Draft Registration Statement on Form F-1
 Submitted February 4, 2026
 CIK No. 0001981662
Dear Wing Fung Alfred Siu:

 We have reviewed your draft registration statement and have the
following comment.

 Please respond to this letter by providing the requested information
and either submitting
an amended draft registration statement or publicly filing your registration
statement and non-
public draft submissions on EDGAR. If you do not believe a comment applies 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 this letter
and your amended
draft registration statement or filed registration statement, we may have
additional comments.

Draft Registration Statement on Form F-1 submitted February 4, 2026
General

1. We note your disclosure on page 26 that your Proposed Reverse Merger
with SAXA,
 Inc. will not be proceeding. We note your disclosure in your Form 6-K
filed on
 November 5, 2026, that states you have "signed an engagement letter
effective October
 30, 2025 with SAXA, Inc. ( SAXA ) to act as the worldwide agent for
the tokenization
 of an initial US$100 million tranche of SAXA s gold-backed assets."
You also disclosed
 in your Form 6-K filed on December 2, 2025 that you are "exploring
exploring a
 potential reverse merger with SAXA, Inc., which would provide access to
a portfolio of
 mining assets, including a validated gold and silver." Please clarify
whether you are
 February 27, 2026
Page 2

 pursuing any transaction with SAXA, Inc. We were unable to locate the
announcement
 of the termination of the proposed reverse merger transaction. If you
have entered into
 any material agreement with SAXA, Inc., please file such agreement as an
exhibit to
 your registration statement.
 Please contact Nicholas O'Leary at 202-551-4451 or Lauren Nguyen at
202-551-3642
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Steve Lin, Esq.
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