United States securities and exchange commission logo

                             May 6, 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
Statement on Form F-1
                                                            Filed May 4, 2020
                                                            File No. 333-237990

       Dear Mr. Shi:

              We have reviewed your 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

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-1

       Prospectus Summary
       Recent Developments, page 6

   1.                                                   We note your
preliminary estimates of certain results of operations for the three months
                                                        ended March 31, 2020,
and your statement warning that there are no guarantees that
                                                        revenues will grow or
remain at similar levels for the rest of 2020. In light of the
                                                        continuing effects of
the pandemic well into the second quarter and the likely adverse
                                                        impact of the pandemic
for the foreseeable future, you should consider expanding your
                                                        discussion to discuss
the reasonably known likely effects of the pandemic on your results
                                                        of operations and
financial condition for 2020.
 Yimeng Shi
uCloudlink Group Inc.
May 6, 2020
Page 2
Risk Factors
Risks Related to Doing Business in China, page 49

2.    We note your risk factor discussion of limitations on the ability of the
PCAOB to conduct
      investigations of your auditor. Include an additional risk factor
describing the difficulties
      in effecting service of legal process, enforcing foreign judgments or
bringing actions in
      China based on foreign laws. Highlight recent developments (e.g. Article
177 of PRC
      Securities Law effective March 2020) possibly further limiting an
overseas regulator from
      conducting investigations or from collecting evidence within the PRC.

3.    Please supplementally provide us with 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,
      present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
      not they retain copies of the communications.
        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

        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 6, 2020 Page 2
cc:       Z. Julie Gao
FirstName LastName