August 22, 2019

Yimeng Shi
Chief Financial Officer
uCloudlink Group Inc.
Room 2118-2119, 21/F, One Pacific Centre
414 Kwun Tong Road, Kwun Ton
Kowloon, Hong Kong

       Re: uCloudlink Group Inc.
           Amendment No. 3 to
           Draft Registration Statement on Form F-1
           Submitted August 15, 2019
           CIK No. 0001775898

Dear Mr. Shi:

      We have reviewed your amended draft registration statement and have the
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

Amendment No. 3 to Draft Registration Statement on Form F-1


1.     We note your presentation of certain key metrics at the forepart of the
       statement. Please revise to balance your presentation of revenue growth
with a measure of
       income, such as net income/loss.
 Yimeng Shi
FirstName LastNameYimeng Shi
uCloudlink Group Inc.
Comapany NameuCloudlink Group Inc.
August 22, 2019
Page 2
August 22, 2019 Page 2
FirstName LastName
Notes to Unaudited Interim Condensed Consolidated Financial Statements
22. Commitments and contingencies, page F-73

2.       We note that a complaint was filed by SIMO Holding Inc. (SIMO) in the
United States
         District Court for the Southern District of New York, alleging patent
infringements. You
         disclose that, "the trial judge delivered a final judgement in June
2019, and the Group
         estimates that the maximum amount of loss in an unfavorable outcome
will be
         approximately US$8.5 million. The Group intends to file an appeal of
the court ruling in
         the United States Court of Appeals for the Federal Circuit." You
further state that, "The
         Group is unable, however, to predict the outcome of these proceedings
given their current
         status and no accrual has been recorded by the Group as of June 30,
2019 in respect of
         these proceedings." We understand that you intend to appeal the
verdict; however, it is
         unclear to us why you cannot estimate an accrual based on the current
final judgement
         against you. Please clarify or revise accordingly.
        You may contact Inessa Kessman, Senior Staff Accountant, at (202)
551-3371 or Robert
S. Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions
comments on the financial statements and related matters. Please contact
Gregory Dundas,
Attorney-Adviser, at (202) 551-3436 or Larry Spirgel, Assistant Director, at
(202) 551-3810 with
any other questions.


                                                             Division of
Corporation Finance
                                                             Office of
cc:      Z. Julie Gao