United States securities and exchange commission logo

                          May 28, 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
                                                            Amendment No. 1 to
Statement on Form F-1
                                                            Filed May 22, 2020
                                                            File No. 333-237990

       Dear Mr. Shi:

             We have reviewed your amended 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 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

              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 May
6, 2020 letter.

       Amendment No. 1 to Form F-1

       Risk Factors
       Your Investment in the ADSs may be impacted if we are encouraged to
issue CDRs in the future,
       page 67

   1.                                                   Please explain how your
ADSs might be negatively impacted if you are encouraged to
                                                        issue CDRs in the
 Yimeng Shi
uCloudlink Group Inc.
May 28, 2020
Page 2
Financial Statements
22. Subsequent Events, page F-80

2.    Refer to the disclosure of the issuance of new share options. Please
disclose the total fair
      value of the options issued in April 2020 and tell us how you determined
this valuation.
      Also, please discuss in MD&A the number of options that will be
exercisable at the
      commencement date of exercise. Disclose the total compensation expense
from all issued
      options that you anticipate will be recognized upon the commencement date
of exercise.
      Clarify on page F-21 and elsewhere in your disclosures, as applicable,
what it means to
      recognize compensation expense on a graded vesting basis.
        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
May 28, 2020 Page 2
cc:       Z. Julie Gao
FirstName LastName