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 March 31, 2025

Yujie Chen
Chief Executive Officer
Grande Group Limited
Suite 2701, 27/F., Tower 1
Admiralty Center, 18 Harcourt Road
Admiralty, Hong Kong

 Re: Grande Group Limited
 Amendment No. 2 to Registration Statement on Form F-1
 Filed March 14, 2025
 File No. 333-283705
Dear Yujie Chen:

 We have reviewed your amended 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. Unless
we note
otherwise, any references to prior comments are to comments in our February 14,
2025 letter.

Amended Registration Statement on Form F-1
Regulatory Development in the PRC and Permission Required, page 12

1. This sub-section appears to discuss two separate issues. The first, is
the impact on you
 and this offering in particular from the Trial Administrative Measures.
The second is
 the impact of those measures where you provide advisory and other
services for
 businesses in the PRC as they attempt to offer securities or otherwise
raise capital in
 Hong Kong. Given the substantial potential impact of the Trial Measures
on your
 business servicing PRC based clients, please revise this section to
discuss those
 impacts under an appropriate heading. Also, revise to clarify aggregate
amount of
 your overall advisory and other services you provide to PRC based
companies.
 March 31, 2025
Page 2
2. We note the statement on page 13 that Mainland China companies who
engaged your
 operating subsidiary for their overseas listing could be subject to
Trial
 Administrative Measures. It is unclear why could is used for
listings that have
 already occurred. Please revise to state whether the clients were
actually subject to the
 measures or disclose the reasons why you are unable to make such a
determination.
 Based on the disclosures, it appears that the risks associated with
sponsoring
 Mainland China clients are qualitatively and potentially materially
different
 depending on whether the clients were actually subject to the measures.
3. We note the statement on page 14 that your operating subsidiary is
not subject to the
 jurisdiction of the CSRC. Please reconcile with the fact that the
operating subsidiary
 is registered with the CSRC under Article 21 of the Trial
Administrative Measures,
 as stated in the first sentence on page 14 and elsewhere. Please
summarize Article 21
 as it applies to the operating subsidiary.
The operation of the Operating Subsidiary is subject to extensive, page 33

4. This risk factor currently discusses both the evolving regulatory
landscape for your
 business in Hong Kong, as well as the possible impact of PRC law on your
business
 providing services for PRC based clients. Revise this section to
separate the
 discussion related to the potential impact of PRC statute, regulations
and regulatory
 oversight on your business in a separate risk factor under an
appropriately descriptive
 heading. Investors must be able to distinguish the risks you face by
serving PRC
 based businesses and other clients who are seeking to list in Hong Kong
or other non-
 PRC financial markets.

 Please contact Victor Cecco at 202-551-2064 or Lory Empie at
202-551-3714 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Robert Arzonetti at 202-551-8819 or Christian Windsor at 202-551-3419
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Yuning Grace Bai
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