United States securities and exchange commission logo

                              October 14, 2021

       Chaohui Chen
       Director and Chief Executive Officer
       uCloudlink Group Inc.
       Unit 2214-Rm1, 22/F, Mira Place Tower A
       132 Nathan Road, Tsim Sha Tsui
       Kowloon, Hong Kong

                                                        Re: uCloudlink Group
                                                            Amendment No. 2 to
Registration Statement on Form F-3
                                                            Filed September 29,
                                                            File No. 333-257782

       Dear Mr. Chen:

             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
August 13, 2021, letter.

       Amendment No. 2 to Form S-3 filed on September 29, 2021

       Cover Page

   1.                                                   We note your added
disclosure in response to prior comment 3. Please revise to refer to
                                                        the VIE entities and
their subsidiaries under a distinct set of terms throughout the filing
                                                        rather than combining
the terms,    we,       our company,       our,    or    uCloudlink" to refer
                                                        both the holding
company and operating entities.
       Prospectus Summary
       Summary of Risk Factors, page 11

   2.                                                   We note your revised
disclosure in reponse to prior coment 5. Please clarify that the
 Chaohui Chen
uCloudlink Group Inc.
October 14, 2021
Page 2
      enforcement of laws and that rules and regulations in China can change
quickly with little
      advance notice; and the Chinese government may intervene or influence
your operations
      at any time, or may exert more control over offerings conducted overseas
and/or foreign
      investment in China-based issuers, which could result in a material
change in your
      operations and/or the value of your ADSs. Please also acknowledge in the
      summary that any actions by the Chinese government to exert more
oversight and control
      over offerings that are conducted overseas and/or foreign investment in
      issuers 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.
        Please contact Austin Pattan, Law Clerk, at (202) 215-1319 or Jan Woo,
Legal Branch
Chief, at (202) 551-3453 with any other questions.

FirstName LastNameChaohui Chen
                                                             Division of
Corporation Finance
Comapany NameuCloudlink Group Inc.
                                                             Office of
October 14, 2021 Page 2
cc:       Shu Du
FirstName LastName