United States securities and exchange commission logo

                            May 23, 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. 6 to
Registration Statement on Form F-3
                                                            Filed April 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
January 12, 2022 letter.

       Amendment No. 6 to Registration Statement on Form F-3

       Cover Page

   1.                                                   Provide a description
of how cash is transferred through your organization and disclose
                                                        your intentions to
distribute earnings or settle amounts owed under the VIE agreements on
                                                        the cover page.
   2.                                                   We note your disclosure
that you have concluded under accounting guidance that you are
                                                        the primary beneficiary
of the former VIEs. Please clarify on the cover page that you
                                                        reached this
determination for accounting purposes.
   3.                                                   We note your disclosure
that you have been added to the provisional list of Commission
 Chaohui Chen
uCloudlink Group Inc.
May 23, 2022
Page 2
      Identified Issuers. Please clarify that the company will be added to the
conclusive list or
      explain why you believe this to be incorrect.
Our Company, page 4

4.    We note your response to our prior comments 1 and 2. In addition to the
cover page
      disclosure, please include an expanded discussion of how the Holding
Foreign Companies
      Accountable Act and related regulations will affect your company in the
      summary as well.
Our Holding Company Structure and Contractual Arrangements with the Former
Interest Entities, page 8

5.    Remove the arrowheads from the chart illustrating your corporate
structure and
      contractual arrangements with the former VIEs, as these imply ownership
and control.
Summary of Risk Factors, page 12

6.    We are unable to find responsive disclosure with respect to our prior
comment 3. Provide
      specific 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
May 23, 2022 Page 2
cc:       Shu Du
FirstName LastName