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 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

 October 10, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

 Attention: Conlon Danberg and Lauren Nguyen

 Re: NewGenIvf Group Limited
Registration Statement on Form
F-1
Filed September 15, 2025
File No. 333-290284

 Ladies and Gentlemen:

 We submit this letter in response
to the written comments of the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission ")
received on September 29, 2025 (the " Comment Letter ") to the above-referenced Registration Statement on Form F-1 submitted
to the Commission by the NewGenIvf Group Limited (the " Company ") on September 15, 2025 (the " Registration
Statement ").

 To assist your review, set
forth below in bold are the comments of the Staff contained in the Comment Letter. Immediately below each reproduced comment is the response
of the Company with respect thereto.

 In addition, the Company has
revised the Registration Statement in response to the Staff's comments and is, concurrently with the submission of this letter,
publicly filing the revised Registration Statement (" Revised Registration Statement "), which reflects the revisions
described in the Company's responses below and clarifies certain other information. The page numbers in the text of the Company's
responses included below correspond to the page numbers in the Revised Registration Statement. Unless otherwise indicated, capitalized
terms used herein have the meanings assigned to them in the Registration Statement.

 Comment Letter Dated September 29, 2025

 Recent Development

 Strategic Investments in Digital Assets, page 23

 1. Staff's Comment: We note your revised
disclosure in response to prior comment 1. Please revise to address the following matters:

 ● Describe more specifically what you mean by "investing
$30 million in staking the digital asset SOL" and provide an estimated timeline for your Solana strategy plan.

 Securities and Exchange Commission

 Division of Corporate Finance

 Office of Industrial Applications and Services

 October 10, 2025

 ● Disclose the material terms of your custody arrangements,
and file your agreement with OSL Limited as an exhibit to your registration statement if material.

 ● Disclose the scope and limitations of the insurance coverage
that OSL Limited provides and discuss whether OSL Limited's coverage is shared by its other custody customers, and whether that
could result in the coverage being insufficient to compensate you for losses.

 ● Disclose with specificity the bonding and unbonding periods
associated with staking SOL.

 ● Disclose the percentage of your SOL holdings currently staked
and whether you have a target percentage of your SOL holdings that you intend to stake.

 ● Disclose the percentage of staking rewards earned, or to be
earned, from your staked SOL to which you are entitled pursuant to your staking arrangements.

 Response: The
Company respectfully acknowledges the Staff's comment and advises the Staff that it has revised the risk factor disclosure on
page 23, and pages 26-27.

 Risk Factors

 Risks Related to Government Regulation

 Advertising or offering of gender selection services in certain
jurisdictions in which NewGenIvf operates…page 51

 2. Staff's Comment: We note your revisions
in response to prior comment 2. You disclose that "On April 25, 2025, Wing Fung Alfred Siu and Hei Yue Tina Fong, and several other
individuals were arrested in Hong Kong for allegedly violating certain sections of the HRTO which prohibit using reproductive technologies
for sex selection, advertising sex selection services, commercial surrogacy arrangements, and advertising surrogacy arrangements."
Please revise this risk factor to specifically describe with more detail the reasons for the arrests of certain of your officers and
employees by the relevant authorities in Hong Kong. Please also clarify if these charges are being brought forth pursuant to the HRTO
and disclose whether the charges are specific to the company and/or your officers, directors and employees.

 Response: The Company
respectfully acknowledges the Staff's comment and advises the Staff that it has revised the risk factor disclosure on page 51.

 3. In your revised disclosure, you state that you "do not
advertise or promote gender selection services in Hong Kong, and all such marketing activities are carried out outside of Hong Kong or
by agents outside of Hong Kong," and that you "have not been, nor do [you] expect to be, materially impacted by any such increased
enforcement of the HRTO." You also state that you "do not expect any material impact on our ability to generate revenue from
Chinese clients, as [y]our PRC-sourced revenues derived from clients in mainland China and Hong Kong are generated through referrals
from PRC agents, with payments being made by the clients directly to the local clinics." Please expand the risk factor to describe
any consequences to you if the regulatory authorities in Hong Kong deems your determination inconsistent from the HRTO.

 Response: The Company
respectfully acknowledges the Staff's comment and advises the Staff that it has revised the risk factor disclosure on page 51.

 ***

 We hope that the foregoing
has been responsive to the Staff's comments. If you have any questions related to this letter, please contact Steve Lin of Han Kun
Law at +852 2820 5600 or by email at steve.lin@hankunlaw.com.

 [ Signature Page Follows ]

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 Securities and Exchange Commission

 Division of Corporate Finance

 Office of Industrial Applications and Services

 October 10, 2025

 Very truly yours,

 NewGenIvf Group Limited

 By:
 /s/ Wing Fung Alfred Siu

 Name:
 Wing Fung Alfred Siu

 Title:
 Chief Executive Officer

 Via E-mail:

 cc:
 Steve Lin Han Kun Law Offices LLP

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