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CORRESP
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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

 March 2, 2026

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

 Attention: Nicholas O'Leary and Lauren Nguyen

 Re:
 NewGenIvf Group Limited
Draft Registration Statement on Form F-1
 Submitted February 4, 2026
 CIK No. 0001981662

 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 February 27, 2026 (the " Comment Letter ") to the above-referenced Draft Registration Statement on Form F-1
submitted to the Commission by the NewGenIvf Group Limited (the " Company ") on February 4, 2026 (the " Draft
Registration Statement ").

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

 In addition, the Company has
revised the Draft Registration Statement in response to the Staff's comment and is, concurrently with the submission of this letter,
publicly filing the revised Draft Registration Statement (" 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 response
included below corresponds to the page numbers in the Registration Statement. Unless otherwise indicated, capitalized terms used herein
have the meanings assigned to them in the Registration Statement.

 Securities and Exchange Commission

 Division of Corporate Finance

 Office of Industrial Applications and Services

 March 2, 2026

 Comment Letter Dated February 27, 2026

 General

 1. Staff's Comment: 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 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 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.

 Response: The Company
respectfully acknowledges the Staff's comment and advises the Staff that it has revised the disclosure on page 26.

 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

 March 2, 2026

 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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