SecProbe.io

CORRESP
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filename1.htm

September 24, 2026

VIA EDGAR

Division of Corporation Finance

Office of Industrial Applications and Services

Securities and Exchange Commission

Attention: Juan Grana and Lauren Nguyen

    Re:

    NewGenIvf Group Limited

    Registration Statement on Form F-1

    Filed September 10, 2026

    File No.: 333-298442

Ladies and Gentlemen:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, NewGenIvf Group Limited (the “Company”)
hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1 (the “Registration Statement”)
be accelerated to and that the Registration Statement become effective at 4:00 p.m., Eastern Time, on September 28, 2026, or as soon thereafter
as practicable.

If there is any change in
the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making
an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461. The request may
be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Han Kun Law Offices LLP.

The Company understands that
the representatives of the placement agent of the offering, have joined in this request in a separate letter filed with the Securities
and Exchange Commission (the “Commission”) today.

The Company hereby acknowledges
the following:

    ●
    should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    ●
    the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

[Signature page follows]

    Yours sincerely,

    NewGenIvf Group Limited

    By:
    /s/ Wing Fung Alfred Siu

    Name:
    Wing Fung Alfred Siu

    Title:
    Chief Executive Officer