United States securities and exchange commission logo

                           January 12, 2022

       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. 5 to
Registration Statement on Form F-3
                                                            Filed October 28,
                                                            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
November 9, 2021 letter.

       Amendment No. 5 to Draft Registration Statement on Form F-3

       Prospectus Summary, page 1

   1.                                                   Disclose whether your
auditor is subject to the determinations announced by the PCAOB
                                                        on December 16, 2021
and whether and how the Holding Foreign Companies
                                                        Accountable Act and
related regulations will affect your company.
   2.                                                   Update your disclosure
to reflect that the Commission adopted rules to implement the
                                                        HFCAA and that,
pursuant to the HFCAA, the PCAOB has issued its report notifying the
                                                        Commission of its
determination that it is unable to inspect or investigate completely
                                                        accounting firms
headquartered in mainland China or Hong Kong.
 Chaohui Chen
uCloudlink Group Inc.
January 12, 2022
Page 2
Summary of Risk Factors, page 12

3.    Provide cross-references to your detailed discussion of risks facing the
company and the
      Please contact Austin Pattan, Staff Attorney, at (202) 551-6756 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 Technology
January 12, 2022 Page 2
cc:       Shu Du
FirstName LastName