United States securities and exchange commission logo

                              September 8, 2022

       Yimeng Shi
       Chief Financial 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
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2021
                                                            Filed April 27,
                                                            File No. 001-39302

       Dear Mr. Shi:

             We have reviewed your filing and have the following comment. In
our comment, we
       may ask you to provide us with information so we may better understand
your disclosure.

              Please respond to this comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comment applies to your facts and circumstances, please tell us why in
your response. After
       reviewing your response to thiscomments, we may have additional

       Form 20-F for the Fiscal Year Ended December 31, 2021

       Note 19. Other Investments, page F-39

   1.                                                   You disclose a
significant amount of current and long-term Other Investments that
                                                        include investments in
debt and equity securities. Please revise to provide, and tell us your
                                                        consideration of, the
information required by ASC 320-10-50, ASC 321-10-50 and ASC
                                                        820-10-50, as
applicable, including the classification information required by major
                                                        security type and fair
value measurement methodology and levels used to value
                                                        these investments.
Revise your discussion of liquidity and capital resources on page
                                                        101 to expand and
clarify the disclosure of these products comprising your
                                                        Other investments.
               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.
 Yimeng Shi
uCloudlink Group Inc.
September 8, 2022
Page 2

       You may contact Joseph Cascarano, Senior Staff Accountant, at (202)
or Robert S. Littlepage, Accountant Branch Chief, at (202) 551-3361 with any

FirstName LastNameYimeng Shi                              Sincerely,
Comapany NameuCloudlink Group Inc.
                                                          Division of
Corporation Finance
September 8, 2022 Page 2                                  Office of Technology
FirstName LastName