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                                                            August 27, 2026

Wing Fung Alfred Siu
Chief Executive Officer
NewGenIvf Group Limited
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 Limited
            Registration Statement on Form F-1
            Filed August 20, 2026
            File No. 333-298442
Dear Wing Fung Alfred Siu:
     We have conducted a limited review of your registration statement and have
the following
comments.
       Please respond to this letter by amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to this letter, we may have additional comments.

Registration Statement on Form F-1
Prospectus Summary
Exclusive Agency Agreement with PredicXion Group Limited, page 29

1.     We note your response to comment 2, including your revised disclosure on
page 29. You
       state that the agency arrangement is a separate commercial initiative
that leverages the
       Company   s established presence, business relationships, local market
knowledge and
       professional network across the Asia-Pacific region. Please revise to
further discuss the
       specific services to be rendered by NewGenIvf in connection with the
promotion,
       marketing and facilitation of the K25.ai platform in the referenced
markets.
 August 27, 2026
Page 2
Audited Consolidated Financial Statements, page F-1

2.     We note your disclosure that the company effected a 1-for-3 reverse
stock split of its
       issued and unissued shares on July 6, 2026, and that the company will be
effecting a 1-for-
       3 reverse stock split of its issued and unissued shares on September 1,
2026. Please revise
       your audited financial statements to reflect the reverse stock split
effected on July 6, 2026.
       Please also revise your audited financial statements to reflect the
reverse stock split
       contemplated for September 1, 2026, once effected.

        We remind you that the company and its management are responsible for
the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action
by the staff.
       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
       Please contact Juan Grana at 202-551-6034 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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