SecProbe.io

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 Global Engine Group Holding Limited

 Room C, 19/F, World Tech Center,

 95 How Ming Street, Kwun Tong,

 Kowloon, Hong Kong

 February 9, 2026

 VIA EDGAR

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Re:
 Global Engine Group Holding Limited

 Registration Statement on Form F-3 (File No. 333-293151)

 Request For Acceleration of Effectiveness

 Ladies and Gentlemen:

 In accordance with Rule 461 of the General Rules
and Regulations under the Securities Act of 1933, as amended, Global Engine Group Holding Limited (the " Company ")
hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-3 (File No. 333-293151) (the " F-3
Registration Statement ") be accelerated to, and that the F-3 Registration Statement become effective at 9:30 a.m., Eastern
Time, on February 11, 2026, or as soon thereafter as practicable.

 If you have any further questions,
please contact the Company's counsel, Arila Zhou, Esq., of Robinson & Cole LLP, at (212) 451-2908.

 Very truly yours,

 Global Engine Group Holding Limited

 By:
 /s/ Andrew, LEE Yat Lung

 Name:
 Andrew, LEE Yat Lung

 Title:
 Chief Executive Officer, Chairman and Director

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 February 6, 2026

Andrew Lee
Chief Executive Officer
Global Engine Group Holding Ltd
Room C, 19/F, World Tech Center
95 How Ming Street, Kwun Tong
Kowloon, Hong Kong

 Re: Global Engine Group Holding Ltd
 Registration Statement on Form F-3
 Filed February 3, 2026
 File No. 333-293151
Dear Andrew Lee:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Mitchell Austin at 202-551-3574 or Jan Woo at
202-551-3453 with any
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Arila E. Zhou
</TEXT>
</DOCUMENT>

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September 13, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Lauren Pierce

 Re: Global Engine Group Holding Ltd.

Registration Statement on Form F-1, as amended

File No. 333-266919

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations
under the Securities Act of 1933, as amended (the “Act”), the undersigned hereby joins in the request of Global Engine Group
Holding Ltd. that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective
at 4:00 p.m., Eastern Time, on September 16, 2024, or as soon thereafter as practicable, or at such other time as the Company or its outside
counsel, Winston & Strawn LLP, request by telephone that such Registration Statement be declared effective.

Pursuant to Rule 460 of the General Rules and Regulations of the Securities
and Exchange Commission under the Securities Act of 1933, as amended, please be advised that there will be distributed to each underwriter
or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary
prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advises that it has complied and will continue to comply
with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

* * *

[Signature Page Follows]

    Very truly yours,

    R.F. LAFFERTY & CO., INC.

    By:
    /s/ John Heidenreich

    Name:
    John Heidenreich

    Title:
    Head of Equity Capital Markets

[Signature Page to Underwriters’ Acceleration
Request Letter]

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GLOBAL ENGINE GROUP HOLDING LIMITED

Room C, 19/F, World Tech Centre

95 How Ming Street, Kwun Tong

Kowloon, Hong Kong

September 13, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:
    Global Engine Group Holding Limited

    Registration Statement on Form F-1, as amended (File No. 333-266919)

    Request For Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Global Engine Group Holding Limited (the “Company”)
hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1/A (the “F-1 Registration
Statement”) be accelerated to and that the F-1 Registration Statement become effective at 4:00 p.m., Eastern Time, on September
16, 2024, or as soon thereafter as practicable.

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.

If you have any further questions,
please contact the Company’s U.S. securities counsel, Arila Zhou, Esq., of Robinson & Cole LLP, at (212) 451-2908.

    Very truly yours,

    Global Engine Group Holding Limited Inc.

    By:

    /s/ Andrew, LEE Yat Lung

    Name:
    Andrew, LEE Yat Lung

    Title:
    Chief Executive Officer

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September 29, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Lauren Peirce

    Re:
    Global Engine Group Holding Limited

Registration Statement on Form F-1, as amended

File No. 333- 266919

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the “Act”), the undersigned hereby joins in the request of Global Engine Group Holding
Limited that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at
4:00 p.m., Eastern Time, on September 29, 2023, or as soon thereafter as practicable, or at such other time as the Company or its outside
counsel, Robinson & Cole LLP, request by telephone that such Registration Statement be declared effective.

Pursuant to Rule 460 of the General Rules and Regulations of the Securities
and Exchange Commission under the Securities Act of 1933, as amended, please be advised that there will be distributed to each underwriter
or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary
prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advises that it has complied and will continue to comply
with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

    Very truly yours,

    PRIME NUMBER CAPITAL LLC,

    By:
    /s/ Xiaoyan
Jiang

    Name:
    Xiaoyan Jiang

    Title:
    Chairwoman

[Signature Page to Underwriter’s
Acceleration Request Letter]

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September 29, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

100 F Street, N.E.

Washington, D.C. 20549

 Attention: Lauren Peirce

 Re: Global Engine Group Holding Limited

Registration Statement on Form F-1, as amended

File No. 333- 266919

Ladies and Gentlemen:

Reference is made to the letter request of Global
Engine Group Holding Limited (the “Company”) for acceleration of effectiveness of the above referenced Registration Statement
submitted to the U.S. Securities and Exchange Commission (the “Commission”) on September 29, 2023, pursuant to Rule 461 under
the Securities Act of 1933, as amended (the “Acceleration Request”).

The undersigned, as the sole underwriter, hereby
respectfully requests that the Commission withdraw the Acceleration Request and refrain from declaring the Registration Statement effective.

* * *

[Signature Page Follows]

    Very truly yours,

    PRIME NUMBER CAPITAL LLC,

    By:
    /s/ Xiaoyan Jiang

    Name:
    Xiaoyan Jiang

    Title:
    Chairwoman

[Signature Page to Underwriter’s Acceleration Request Withdrawal
Letter]

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GLOBAL ENGINE GROUP HOLDING LIMITED

Room C, 19/F, World Tech Centre

95 How Ming Street, Kwun Tong

Kowloon, Hong Kong

September 29, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:
    Global Engine Group Holding Limited

    Registration Statement on Form F-1, as amended (File No. 333-266919)

    Request For Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended, Global Engine Group Holding Limited (the “Company”)
hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1/A (the “F-1 Registration
Statement”) be accelerated to and that the F-1 Registration Statement become effective at 4:00 p.m., Eastern Time, on September
29, 2023, or as soon thereafter as practicable.

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.

If you have any further questions,
please contact the Company’s U.S. securities counsel, Arila E. Zhou, Esq., of Robinson & Cole LLP, at (212) 451-2908.

    Very truly yours,

    Global Engine Group Holding Limited

    By:

    /s/ Andrew, LEE Yat Lung

    Name:
    Andrew, LEE Yat Lung

    Title:
    Chief Executive Officer

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GLOBAL ENGINE GROUP HOLDING LIMITED

Room C, 19/F, World Tech Centre

95 How Ming Street, Kwun Tong

Kowloon, Hong Kong

September 29, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Global Engine Group Holding Limited

    Registration Statement on Form F-1, as amended (File No. 333-266919)

    Withdrawal of Acceleration Request of Effectiveness

    Filed on September 29, 2023

Dear Sir or Madam,

Global Engine Group Holding Limited (the “Company”)
hereby respectfully requests that the U.S. Securities and Exchange Commission consent to the withdrawal of an acceleration request filed
on September 29, 2023 pursuant to Rule 461 under the Securities Act of 1933, as amended, requesting for effectiveness of the above-referenced
Registration Statement on Form F-1 as of 4:00 p.m. Eastern Time, on September 29, 2023.

Following such withdrawal, the Company plans to
submit a new acceleration request.

Please contact the Company’s U.S. securities
counsel, Arila E. Zhou, Esq., of Robinson & Cole LLP, at (212) 451-2908, if you have any questions.

    Very truly yours,

    Global Engine Group Holding Limited

    By:

    /s/ Andrew, LEE Yat Lung

    Name:
    Andrew, LEE Yat Lung

    Title:
    Chief Executive Officer

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GLOBAL ENGINE GROUP HOLDING LTD

August 29, 2023

Lauren Pierce

Staff Attorney

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: Global Engine Group Holding
Ltd.

Amendment No. 5 to Registration Statement on Form F-1

Filed May 31, 2023

File No. 333-266919

Dear Ms. Pierce:

This letter is in response
to the oral comments (the “Oral Comments”) from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) addressed to Global Engine Group Holding Ltd. (the “Company,” “we,” and “our”)
as provided by the Staff via telephone message on June 14, 2023. For ease of reference, we have presented a summary of the text of the
Oral Comments in this response. The Amendment No. 6 to Registration Statement on Form F-1 (the “Registration Statement”) is
being filed to accompany this letter.

Amendment No. 5 to Registration Statement on
Form F-1 filed May 31, 2023

Risk Factors

There remain some uncertainties…, page
33

    1.
    Please revise your disclosure discussing the Trial Administrative Measures of Overseas Securities Offering and Listing by Domestic Companies, promulgated by the CSRC, to reflect current effective status.

Response: We respectfully advise
the Staff that we have revised the disclosures on page 33 of the Registration Statement to reflect the current effective status of the
Trial Administrative of Overseas Securities Offering and Listing by Domestic Companies.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Arila Zhou, Esq., of
Robinson & Cole LLP, at (212) 451-2908.

Very truly yours,

    By:
    /s/ Andrew Lee

    Andrew Lee

    Chief Executive Officer

cc: Arila Zhou

Robinson & Cole LLP

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GLOBAL ENGINE GROUP HOLDINGS LTD

March 1, 2023

Lauren Pierce

Staff Attorney

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: Global
Engine Group Holding Ltd.

Amendment No. 2 to Registration Statement on Form F-1

Filed January 11, 2023

File No. 333-266919

Dear Ms. Pierce:

This letter is in response
to the letter dated February 17, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Global Engine Group Holding Ltd. (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. The Amendment No. 4 to Registration Statement
on Form F-1 (the “Registration Statement”) is being filed to accompany this letter.

Form F-1 filed February 8, 2023

Management, page 69

    1.
    We note that, in response to our prior comment 1, Mr. Lee signed the registration statement in the capacity of Principal Financial Officer and Principal Accounting Officer. Please disclose clearly, if true, that he is currently serving as your acting Principal Financial Officer and Principal Accounting Officer.

Response: We respectfully advise
the Staff that we have revised the disclosures on page 69 of the Registration Statement to disclose that Andrew, LEE Yat Lung currently
serves as acting Principal Financial Officer and Accounting Officer of the Company and Mr. Lee serves in such capacity until we appoint
a Chief Financial Officer upon the effectiveness of the Registration Statement.

General

    2.
    You disclose on page ALT-1 that selling shareholders will be offering the shares at $4.50 per share but state on the cover page that the selling shareholders will be offering the shares at prevailing market prices or privately negotiated prices after close of the initial public offering. Please clarify.

Response: We respectfully advise
the Staff that we have revised the disclosure on page Alt-1 of the Registration Statement to clarify that any shares sold by the selling
shareholders will occur at prevailing market prices or in privately negotiated prices after close of the initial public offering and listing
of our ordinary shares on Nasdaq, and such sales by the selling shareholders will not occur until after our ordinary shares begin trading
on Nasdaq.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Arila Zhou, Esq., of
Robinson & Cole LLP, at (212) 451-2908.

Very truly yours,

    By:
    /s/ Andrew Lee

    Andrew Lee

    Chief Executive Officer

cc: Arila Zhou

Robinson & Cole LLP

United States securities and exchange commission logo
February 17, 2023
Andrew Lee
Chief Executive Officer
Global Engine Group Holding Ltd
Room C, 19/F, World Tech Centre
95 How Ming Street, Kwun Tong
Kowloon, Hong Kong
Re:Global Engine Group Holding Ltd
Amendment No. 3 to Registration Statement on Form F-1
Filed February 8, 2023
File No. 333-266919
Dear Andrew Lee:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our January 25, 2023 letter.
Form F-1 filed February 8, 2023
Management, page 69
1.We note that, in response to our prior comment 1, Mr. Lee signed the registration
statement in the capacity of Principal Financial Officer and Principal Accounting Officer.
Please disclose clearly, if true, that he is currently serving as your acting Principal
Financial Officer and Principal Accounting Officer.
General
2.You disclose on page ALT-1 that selling shareholders will be offering the shares at $4.50
per share but state on the cover page that the selling shareholders will be offering the

 FirstName LastNameAndrew Lee
 Comapany NameGlobal Engine Group Holding Ltd
 February 17, 2023 Page 2
 FirstName LastName
Andrew Lee
Global Engine Group Holding Ltd
February 17, 2023
Page 2
shares at prevailing market prices or privately negotiated prices after close of the initial
public offering.  Please clarify.
            You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Lauren Pierce, Staff
Attorney, at (202) 551-3887 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Arila Zhou

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GLOBAL ENGINE GROUP HOLDINGS LTD

February 7, 2023

Lauren Pierce

Staff Attorney

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

Re: Global Engine Group Holding
Ltd.

Amendment No. 2 to Registration Statement on Form F-1

Filed January 11, 2023

File No. 333-266919

Dear Ms. Pierce:

This letter is in response
to the letter dated January 25, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Global Engine Group Holding Ltd. (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. The Amendment No. 3 to Registration Statement
on Form F-1 (the “Registration Statement”) is being filed to accompany this letter.

Amendment No. 2 to Form F-1

Signatures, page II-4

    1.
    We note that Sung Pui Hei, your Chief Financial Officer Nominee and Director Nominee signed the registration statement. Given that Mr. Sung's appointment as the Chief Financial Officer and director is not effective until the effectiveness of the registration statement, please have the current Chief Financial Officer and Chief Accounting Officer sign the registration statement.

Response: We respectfully advise
the Staff that Andrew, LEE Yat Lung has signed the Registration Statement filed with the Commission on February 7, 2023 in the capacity
of Principal Executive Officer, Principal Financial Officer and Accounting Officer of the Company.

General

    2.
    Please revise page ALT-1 of the selling shareholder prospectus to indicate that sales will occur at prevailing market prices or in privately negotiated prices once the ordinary shares are listed on the Nasdaq and that this offering will not occur unless the shares are trading on Nasdaq.

Response: We respectfully advise
the Staff that we have revised the disclosure on page Alt-1 of the Registration Statement to indicate that sales by selling shareholders
will occur at prevailing market prices or in privately negotiated prices once the ordinary shares are listed on Nasdaq and that the resale
offering will not occur unless our ordinary shares are trading on Nasdaq.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Arila Zhou, Esq., of
Robinson & Cole LLP, at (212) 451-2908.

Very truly yours,

    By:
    /s/ Andrew Lee

    Andrew Lee

    Chief Executive Officer

cc: Arila Zhou

Robinson & Cole LLP

United States securities and exchange commission logo
January 25, 2023
Andrew Lee
Chief Executive Officer
Global Engine Group Holding Ltd
Room C, 19/F, World Tech Centre
95 How Ming Street, Kwun Tong
Kowloon, Hong Kong
Re:Global Engine Group Holding Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed January 11, 2022
File No. 333-266919
Dear Andrew Lee:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Amendment No. 2 to Form F-1
Signatures, page II-4
1.We note that Sung Pui Hei, your Chief Financial Officer Nominee and Director Nominee
signed the registration statement.  Given that Mr. Sung's appointment as the Chief
Financial Officer and director is not effective until the effectiveness of the registration
statement, please have the current Chief Financial Officer and Chief Accounting Officer
sign the registration statement.
General
2.Please revise page ALT-1 of the selling shareholder prospectus to indicate that sales will
occur at prevailing market prices or in privately negotiated prices once the ordinary shares

 FirstName LastNameAndrew Lee
 Comapany NameGlobal Engine Group Holding Ltd
 January 25, 2023 Page 2
 FirstName LastName
Andrew Lee
Global Engine Group Holding Ltd
January 25, 2023
Page 2
are listed on the Nasdaq and that this offering will not occur unless the shares are trading
on Nasdaq.
            You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Lauren Pierce, Staff
Attorney, at (202) 551-3887 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Arila Zhou

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GLOBAL ENGINE GROUP HOLDINGS LTD

January 11, 2023

Lauren Pierce

Staff Attorney

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: Global Engine Group Holding
Ltd.

Amendment No 1 to Registration Statement on Form F-1

Filed December 7, 2022

File No. 333-266919

Dear Ms. Pierce:

This letter is in response
to the letter dated December 23, 2022, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Global Engine Group Holding Ltd. (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. The Amendment No. 2 to Registration Statement
on Form F-1 (the “Registration Statement”) is being filed to accompany this letter.

Form F-1 filed December 7, 2022

Risk Factors

We have a substantial customer concentration…,
page 19

1. Please clarify your disclosure
regarding your significant customers for the fiscal year ended June 30, 2022. For example, you state that had two major third-party customers
but then list four companies; you also identify VNET Group, Inc. and Diyixian.com Limited as a single third-party customer. Additionally,
you disclose that you have entered into two separate agreements with Diyixian.com Limited but have filed only one of these agreements
as an exhibit. Please tell us what consideration you gave to filing the other agreement as an exhibit. Similarly, please file the agreements
with your related party customers, Macro Systems Limited and DataCube Research Center Limited, or explain why they are not required to
be filed. Refer to Item 601(b)(10) of Regulation S-K. Finally, it appears that several agreements with your significant customers have
expired or will terminate in 2022. Please address the risks to the company and how the company will be impacted when and if the agreements
terminate.

Response: We respectfully advise
the Staff that we have revised the disclosures on page 19 of the Registration Statement to clarify that for the fiscal year ended June
30, 2022 there were two (2) major third-party customers and one (1) major related-party customer. The two (2) major third-party customers
were (i) VNET Group, Inc. (instead of entering into agreements with VNET Group, Inc., the Company has entered into separate agreements
with its subsidiaries, 21Vianet Group Limited and Diyixian.com Limited, and the revenues derived from these two subsidiaries have been
consolidated and reported under their parent company VNET Group, Inc.) and (ii) Aisly Global Inc.

The Staff noted that we disclosed
entering into two (2) separate agreements with Diyixian.com Limited, but filed only one of these agreements as an exhibit. We respectfully
advise the Staff that we have entered into only one (1) agreement with Diyixian.com Limited and said agreement was previously filed as
Exhibit 10.2 to Amendment No. 1 to the Registration Statement on Form F-1. Such agreement with Diyixian.com Limited, dated January 1,
2020, has a term of one year and expired on December 31, 2020, after which we continue to provide services to such customer without a
written agreement on a periodic basis.

Additionally, the Staff noted
that we should file the agreements with our related party customers, Macro Systems Limited and DataCube Research Center Limited. Pursuant
to such comment, we have filed the agreements with Macro Systems Limited as exhibits to the Registration Statement as Exhibits 10.24,
10.25, 10.26 and 10.27. Our agreement with DataCube Research Center Limited was previously filed as Exhibit 10.21 to Amendment No. 1 to
the Registration Statement on Form F-1 filed with the SEC on December 7, 2022.

Additionally, we have revised
the risk factor disclosures on page 19 of the Registration Statement to clarify the risks and impact to the company due to the termination
or expiration of certain agreements with significant customers.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Arila Zhou, Esq., of
Robinson & Cole LLP, at (212) 451-2908.

Very truly yours,

    By:
    /s/ Andrew Lee

    Andrew Lee

    Chief Executive Officer

Arila Zhou

Robinson & Cole LLP

United States securities and exchange commission logo
December 23, 2022
Andrew Lee
Chief Executive Officer
Global Engine Group Holding Ltd
Room C, 19/F, World Tech Centre
95 How Ming Street, Kwun Tong
Kowloon, Hong Kong
Re:Global Engine Group Holding Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed December 7, 2022
File No. 333-266919
Dear Andrew Lee:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our 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 comment, we may have additional comments.
Form F-1 filed December 7, 2022
Risk Factors
We have a substantial customer concentration..., page 19
1.Please clarify your disclosure regarding your significant customers for the fiscal year
ended June 30, 2022. For example, you state that had two major third-party customers but
then list four companies; you also identify VNET Group, Inc. and Diyixian.com Limited
as a single third-party customer. Additionally, you disclose that you have entered into two
separate agreements with Diyixian.com Limited but have filed only one of these
agreements as an exhibit. Please tell us what consideration you gave to filing the other
agreement as an exhibit. Similarly, please file the agreements with your related party
customers, Macro Systems Limited and DataCube Research Center Limited, or explain

 FirstName LastNameAndrew Lee
 Comapany NameGlobal Engine Group Holding Ltd
 December 23, 2022 Page 2
 FirstName LastName
Andrew Lee
Global Engine Group Holding Ltd
December 23, 2022
Page 2
why they are not required to be filed. Refer to Item 601(b)(10) of Regulation S-K. Finally,
it appears that several agreements with your significant customers have expired or will
terminate in 2022. Please address the risks to the company and how the company will be
impacted when and if the agreements terminate.
            You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Lauren Pierce, Staff
Attorney, at (202) 551-3887 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Arila Zhou

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GLOBAL ENGINE GROUP HOLDINGS LTD

December 6, 2022

Lauren Pierce

Staff Attorney

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: Global Engine Group Holding Ltd.

Registration Statement on Form F-1

Filed August 16, 2022

File No. 333-266919

Dear Ms. Pierce:

This letter is in response
to the letter dated August 31, 2022, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Global Engine Group Holding Ltd. (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. The amendment to Registration Statement
on Form F-1 (the “Registration Statement”) is being filed to accompany this letter. Please note that in addition to including
changes in the Registration Statement to reflect responses to the Staff’s comments, we have revised the Registration Statement to
include alternate pages for a resale prospectus pursuant to which certain selling shareholders will sell their ordinary shares of the
Company.

Registration Statement on Form F-1

Commonly Used Defined Terms, page ii

 1. We have reviewed your response to prior comment no. 2 and noted that dollar equivalent or convenience
translations are generally not permitted. Translations should be made at the exchange rate on the balance sheet date or most recent date
practicable, not both. Additionally, while an issuer filing a registration statement on Form F-3 that incorporates financial statements
previously filed on Form 20-F does not need to amend or otherwise modify these statements to reflect a more current exchange rate in presenting
the convenience translation, this fact pattern does not apply to your registration statement on Form F-1. Please revise to apply the exchange
rate as of the most recent balance sheet date included in the filing to both periods in accordance with Rule 3-20(b)(1) of Regulation

S-X.

Response: We respectfully advise the Staff that
we have revised the disclosures in the Registration Statement to provide US dollar translations of balances as of June 30, 2022 and June
30, 2021 applying the exchange rate as of the most recent balance sheet date included in the Registration Statement.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Arila Zhou, Esq., of
Robinson & Cole LLP, at (212) 451-2908.

Very truly yours,

[Signature Page Follows]

    By:
    /s/ Andrew Lee

    Andrew Lee

    Chief Executive Officer

Arila Zhou

Robinson & Cole LLP

[signature page to the SEC response letter]

2

United States securities and exchange commission logo
August 31, 2022
Andrew Lee
Chief Executive Officer
Global Engine Group Holding Ltd
Room C, 19/F, World Tech Centre
95 How Ming Street, Kwun Tong
Kowloon, Hong Kong
Re:Global Engine Group Holding Ltd
Registration Statement on Form F-1
Filed August 16, 2022
File No. 333-266919
Dear Mr. Lee:
            We have reviewed your registration statement and have the following comment.  In our
comment, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our 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 comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our July 27, 2022 letter.
Registration Statement on Form F-1
Commonly Used Defined Terms, page ii
1.We have reviewed your response to prior comment no. 2 and noted that dollar equivalent
or convenience translations are generally not permitted. Translations should be made at
the exchange rate on the balance sheet date or most recent date practicable, not both.
Additionally, while an issuer filing a registration statement on Form F-3 that incorporates
financial statements previously filed on Form 20-F does not need to amend or otherwise
modify these statements to reflect a more current exchange rate in presenting the
convenience translation, this fact pattern does not apply to your registration statement on
Form F-1. Please revise to apply the exchange rate as of the most recent balance sheet date

 FirstName LastNameAndrew Lee
 Comapany NameGlobal Engine Group Holding Ltd
 August 31, 2022 Page 2
 FirstName LastName
Andrew Lee
Global Engine Group Holding Ltd
August 31, 2022
Page 2
included in the filing to both periods in accordance with Rule 3-20(b)(1) of Regulation S-
X.
            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.
            You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Lauren Pierce, Staff
Attorney, at (202) 551-3887 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Arila Zhou

CORRESP
1
filename1.htm

GLOBAL ENGINE GROUP HOLDING LTD

August 16, 2022

Ms. Lauren Pierce

Division of Corporation Finance

Office of Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re:Global Engine Group Holding Ltd

Amendment No. 1 to Draft Registration Statement
on Form F-1

Submitted on July 15, 2022

CIK No. 0001908705

Dear Ms. Pierce:

This letter is in response to the letter dated
July 27, 2022, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed
to Global Engine Group Holding Ltd (the “Company,” “we,” and “our”). For ease of reference, we have
recited the Commission’s comments in this response and numbered them accordingly. The Registration Statement on Form F-1 (the “Registration
Statement”) is being filed to accompany this letter.

Amendment No. 1 to the Registration Statement
on Form F-1

Cover Page

 1. Please
clarify that all the legal and operational risks associated with being based in and having operations in the PRC also apply to operations
in Hong Kong.

RESPONSE: We respectfully advise the Staff
that we have revised relevant disclosures in the cover page and throughout the Registration Statement to include all the legal and operational
risks associated with being based in and having operations in Hong Kong. Please note that our Company is not based in or having operations
in the PRC.

Commonly Used Defined Terms, page ii

 2. You disclose that translations of balances as of December 31, 2021 are calculated at the rate of US$1.00
= HKD7.7996, and translations of balances as of June 30, 2021 are calculated at the rate of US$1.00 = HKD7.7658. Please revise to apply
the exchange rate as of the most recent balance sheet date included in the filing to both periods. Refer to Rule 3-20(b)(1) of Regulation
S-X. Be advised that the translation should be made at the exchange rate on the balance sheet date or most recent date practicable, if
materially different.

RESPONSE: We respectfully advise the Staff
that the Company follows the SEC financial reporting guidance as follows:

6620.5 Dollar equivalent or convenience
translations are generally not permitted, except that a convenience translation may be presented only for the most recent fiscal year
and any subsequent interim period. Translation should be made at the exchange rate on the balance sheet date or most recent date practicable,
if materially different. The rate used for the convenience translation should generally be the rate that the issuer would use if dividends
were to be paid in U.S. dollars.

6620.6 An issuer filing a registration
statement on Form F-3 that incorporates financial statements previously filed on Form 20-F does not need to amend or otherwise modify
these statements to reflect a more current exchange rate in presenting the convenience translation.

NOTE: Amendment or other modification
is not necessary even if the company has presented a convenience translation on interim data in the registration statement or by reference
to Form 6-K. In this situation, the issuer should disclose in the interim data provided on the Form 6-K that different exchange rates
have been used for the convenience translation.

The Company acknowledge that it should use the
latest balance rate in the filing. However, as per 6620.6 and the note following section 6620, in certain situations, the Company is not
required to amend or modify prior issued financials which the Company analogized for its December 31, 2021 financials.

In
addition, the rate difference between December 31, 2021 (US$1.00=HKD7.7996)
and June 30, 2021(US$1.00 = HKD7.7658) was approximately by 0.43%. Therefore,
the Company’s total assets, total liabilities, revenues, gross profit and net income were understated by 0.43% which is not material
to the Company’s overall financial position and result of operations.

Risk Factors

We rely on a limited number of vendors..., page 20

 3. We
note your response to prior comment 9. In your disclosure, please specify the duration of the agreement made with Nexsen Limited on July
2, 2021.

 RESPONSE: We respectfully advise the Staff
that we have revised relevant disclosures on page 19 to specify the duration of the agreement made with Nexsen Limited on July 2, 2021.

Management’s Discussion and Analysis
of Financial Condition and Results of Operations, page 56

 4. We
note your response to prior comment 6. Please clarify in your disclosure that the financial statements reflect only the activities of
GEL, your operating subsidiary, and the intermediate BVI holding entity has no operations or activity.

RESPONSE: We respectfully advise the Staff
that we have revised relevant disclosures on page 53 to clarify that the financial statements reflect only the activities of GEL, our
operating subsidiary, and both the Company and Global Engine Holdings Limited, our intermediate BVI holding entity, have no operations
or activity.

Industry, page 70

 5. We
note your response to prior comment 11. Please clarify the purpose of including data regarding mobile connectivity and mobile data consumption
and how they relate to your business. Further, please consider adding disclosure identifying your target customers and the general size
of your target market.

RESPONSE: We respectfully advise the Staff
that we have revised relevant disclosures on page 67 to remove the references to mobile connectivity and mobile data consumption. We also
added disclosure identifying our target customers and the general size of our target market on the same page.

Business, page 71

 6. We
note your response to prior comment 12. Please disclose whether the three employees of Boxasone Limited are, under the Cost Assignment
Agreement, working for you full- time.

 RESPONSE: We respectfully advise the Staff
that we have revised relevant disclosures on page 72 to confirm that the three employees of Boxasone Limited are not working for us full-time
under the Cost Assignment Agreement. The percentages of costs of these part-time employees that we share with Boxasone Limited are based
on the estimated services and hours these employees would provide to us.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Arila Zhou, Esq., of
Robinson & Cole LLP, at (212) 451-2908.

Very truly yours,

[Signature Page Follows]

    2

    By:
    /s/ Andrew Lee

    Andrew Lee

    Chief Executive Officer

    Arila Zhou, Esq.

    Robinson & Cole LLP

[signature page to the SEC response letter]

3

United States securities and exchange commission logo
July 27, 2022
Andrew Lee
Chief Executive Officer
Global Engine Group Holding Ltd
Room C, 19/F, World Tech Centre
95 How Ming Street, Kwun Tong
Kowloon, Hong Kong
Re:Global Engine Group Holding Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted on July 15, 2022
CIK No. 0001908705
Dear Mr. Lee:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments. References to prior comments refer to comments in our April 22, 2022 letter.
Amendment No. 1 to the Registration Statement on Form F-1
Cover Page
1.Please clarify that all the legal and operational risks associated with being based in and
having operations in the PRC also apply to operations in Hong Kong.
Commonly Used Defined Terms, page ii
2.You disclose that translations of balances as of December 31, 2021 are calculated at the
rate of US$1.00 = HKD7.7996, and translations of balances as of June 30, 2021 are
calculated at the rate of US$1.00 = HKD7.7658. Please revise to apply the exchange rate
as of the most recent balance sheet date included in the filing to both periods. Refer to

 FirstName LastNameAndrew Lee
 Comapany NameGlobal Engine Group Holding Ltd
 July 27, 2022 Page 2
 FirstName LastName
Andrew Lee
Global Engine Group Holding Ltd
July 27, 2022
Page 2
Rule 3-20(b)(1) of Regulation S-X. Be advised that the translation should be made at the
exchange rate on the balance sheet date or most recent date practicable, if materially
different.
Risk Factors
We rely on a limited number of vendors..., page 20
3.We note your response to prior comment 9. In your disclosure, please specify the duration
of the agreement made with Nexsen Limited on July 2, 2021.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
56
4.We note your response to prior comment 6. Please clarify in your disclosure that the
financial statements reflect only the activities of GEL, your operating subsidiary, and the
intermediate BVI holding entity has no operations or activity.
Industry, page 70
5.We note your response to prior comment 11. Please clarify the purpose of including data
regarding mobile connectivity and mobile data consumption and how they relate to your
business. Further, please consider adding disclosure identifying your target customers and
the general size of your target market.
Business, page 71
6.We note your response to prior comment 12. Please disclose whether the three employees
of Boxasone Limited are, under the Cost Assignment Agreement, working for you full-
time.
            You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Lauren Pierce, Staff
Attorney, at (202) 551-3887 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Arila Zhou

United States securities and exchange commission logo
April 22, 2022
Andrew Lee
Chief Executive Officer
Global Engine Group Holding Ltd
Workshop A, 8/F, Reason Group Tower
403 Castle Peak Road, Kwai Chung
New Territories, Hong Kong
Re:Global Engine Group Holding Ltd
Draft Registration Statement on Form F-1
Submitted on March 25, 2022
CIK No. 0001908705
Dear Mr. Lee:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement submitted March 25, 2022
Cover Page
1.Please revise your disclosure that you have no clients or suppliers who are in mainland
China to clarify the percentage of your revenues generated from Hong Kong.  Also, revise
your disclosure on page ii to remove the exclusion of Taiwan, Hong Kong and Macau
from the definition of the PRC and China.

 FirstName LastNameAndrew Lee
 Comapany NameGlobal Engine Group Holding Ltd
 April 22, 2022 Page 2
 FirstName LastName
Andrew Lee
Global Engine Group Holding Ltd
April 22, 2022
Page 2
2.Please disclose the potential effects of regulation by PRC, including whether these risks
could result in a material change in your operations and/or the value of the securities you
are registering for sale or could significantly limit or completely hinder your ability to
offer or continue to offer securities to investors and cause the value of such securities to
significantly decline or be worthless.
Prospectus Summary, page 1
3.Where you disclose that the audit report included in the prospectus was prepared by U.S.
auditors who are currently inspected by the PCAOB, include a disclosure regarding
whether your auditor is subject to the determinations announced by the PCAOB on
December 16, 2021.
4.We note your disclosure that you are currently not required to obtain permission from any
of the PRC authorities to operate and to issue your shares. Please describe the
consequences to you and your investors if you or your subsidiaries: (i) do not receive or
maintain such permissions or approvals, (ii) inadvertently conclude that such permissions
or approvals are not required, or (iii) applicable laws, regulations, or interpretations
change and you are required to obtain such permissions or approvals in the future.
5.Provide a clear description of how cash is transferred through your organization. Describe
any restrictions on foreign exchange and your ability to transfer cash between entities,
across borders, and to U.S. investors. Describe any restrictions and limitations on your
ability to distribute earnings from the company, including your subsidiaries, to the parent
company and U.S. investors.
6.We note that your subsidiaries constitute a material part of your consolidated financial
statements. Please provide in tabular form a condensed consolidating schedule that
disaggregates the operations and depicts the financial position, cash flows, and results of
operations as of the same dates and for the same periods for which audited consolidated
financial statements are required. The schedule should present major line items, such as
revenue and cost of goods/services, and subtotals and disaggregated intercompany
amounts, such as separate line items for intercompany receivables and investment in
subsidiary. The schedule should also disaggregate the parent company and its
consolidated subsidiaries. Any intercompany amounts should be presented on a gross
basis and when necessary, additional disclosure about such amounts should be included in
order to make the information presented not misleading.
Risk Factors, page 18
7.To the extent material, please include a risk factor describing the potential
for cybersecurity incidents and data breaches and their potential impact on your business.

 FirstName LastNameAndrew Lee
 Comapany NameGlobal Engine Group Holding Ltd
 April 22, 2022 Page 3
 FirstName LastName
Andrew Lee
Global Engine Group Holding Ltd
April 22, 2022
Page 3
We have a substantial customer concentration..., page 19
8.We note that for the year ended June 30, 2021, three major customers accounted for
57.1%, 18.7% and 17.6%, respectively, of the company’s total revenues. Please disclose
the material terms of the agreements with the customers, including the identity of the
customers, the term of the agreements and termination provisions. File the agreements as
exhibits.
We rely on a limited number of vendors, page 19
9.You state that four vendors accounted for 32.7%, 21.2%, 20.0% and 14.5%, respectively,
of the company’s total purchases for the year ended June 30, 2021.  Please disclose the
material terms of your agreements with the vendors, including the identity of the vendors,
term and termination provisions of the agreements, and any minimum purchase
commitments.  File the agreements as exhibits.
Our business operations have been and may continue to be materially and adversely affected...,
page 23
10.You state that you have experienced, and may continue to experience, disruptions or
delays in your supply chain as a result of restrictions in response to COVID-19. Discuss
the nature of the supply chain issues you have experienced and the issues that you expect
to experience. Discuss whether the issues have had or are expected to have a material
adverse effect on the company.
Industry, page 63
11.You state that the Hong Kong telecommunications market mobile penetration rate is
291%. Please explain how the mobile penetration rate of Hong Kong can exceed 100%.
Disclose the time period in which this rate was measured and discuss any underlying
assumptions and limitations of this rate.
Business, page 66
12.Please disclose whether the four employees you disclosed are employed by the Global
Engine Group Holding Limited, Global Engine Holdings Limited, or Global Engine
Limited.  Further, please clarify for which entity you intend to hire employees as part of
your growth strategy.
Management, page 70
13.Please identify the "company specialising in the supply of lighting fittings" for which
Sung Pui Hei is currently the Chief Financial Officer.

 FirstName LastNameAndrew Lee
 Comapany NameGlobal Engine Group Holding Ltd
 April 22, 2022 Page 4
 FirstName LastName
Andrew Lee
Global Engine Group Holding Ltd
April 22, 2022
Page 4
Related Party Transactions, page 76
14.You indicate in the prospectus summary that you have a strategic partnership with China
Information Technology Development which also beneficially owns 10% of the
company's ordinary shares.   Please disclose the material terms of this related party
transaction, including any understandings or agreements between the company and China
Information Technology Development.
Exhibits
15.Please tell us whether you intend to file the consent of Sung Pui Hei who will serve as a
director and Chief Financial Officer immediately upon the effectiveness of the registration
statement.  See Rule 438 of Regulation C.
General
16.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications.
            You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Lauren Pierce, Staff
Attorney, at (202) 551-3887 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Arila Zhou