March 24, 2020

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. 6 to
           Draft Registration Statement on Form F-1
           Submitted March 13, 2020
           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

Draft Registration Statement on Form F-1

Notes to the Consolidated Financial Statements
12. Cash and cash equivalents and short-term deposit, page F-40

1.     Regarding the table on page F-41, please explain to us why the US$
equivalent of 11,795
       as of December 31, 2019 does not equal the corresponding US$ original
currency amount.
 Yimeng Shi
uCloudlink Group Inc.
March 24, 2020
Page 2
Commitments and Contingencies, page F-47

2.    We note your updated disclosure regarding the complaint filed by SIMO
Holdings Inc.
      You describe an adverse ruling from the Court with amended damages of US
      million. In addition, you disclosed that you have deposited the damages
in an escrow
      account in January 2020 while you appeal the ruling. To help us better
understand your
      disclosure, tell us how much of these damages were accrued in your 2019
      statements. The last sentence in your contingencies footnote appears to
indicate that you
      presently have no accruals for any of the legal matters disclosed. If
this is true for the
      SIMO Holdings Inc. matter, please explain why the loss is not probable or
        You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions
comments on the financial statements and related matters. Please contact
Michael C. Foland,
Attorney-Advisor, at (202) 551-6711 or Larry Spirgel, Assistant Director, at
(202) 551-
3815 with any other questions.

FirstName LastNameYimeng Shi
                                                           Division of
Corporation Finance
Comapany NameuCloudlink Group Inc.
                                                           Office of Technology
March 24, 2020 Page 2
cc:       Z. Julie Gao
FirstName LastName