June 5, 2020

VIA EDGAR

Mr. Larry Spirgel, Assistant Director

Mr. Michael C. Foland, Attorney Adviser

Mr. Robert Littlepage, Accounting Branch Chief

Mr. Charles Eastman, Staff Accountant

Office of Technology

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

Response to the Staff’s Comments on the Amendment No. 3 to

Registration Statement on Form F-1 Filed on June 2, 2020

Dear Mr. Spirgel, Mr. Foland, Mr. Littlepage and Mr. Eastman:

On behalf of our client, UCLOUDLINK GROUP INC., a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), we submit to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) this letter setting forth the Company’s response to the comments contained in the Staff’s letter dated June 4, 2020, on the Company’s amendment no. 3 to registration statement on Form F-1 filed on June 2, 2020. The Staff’s comments are repeated below in bold and are followed by the Company’s response. We have included page references in the Revised Registration Statement (as defined below) where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Revised Registration Statement.

U.S. Securities and Exchange Commission

June 5, 2020

Page 2

Concurrently with the submission of this letter, the Company is filing herewith amendment no. 4 to the Company’s registration statement on Form F-1 (the “Revised Registration Statement”) including certain exhibit thereto and a free writing prospectus relating to the changes reflected in the Revised Registration Statement via EDGAR with the Commission.

The Company respectfully advises the Commission that it plans to request that the Commission declare the effectiveness of the Revised Registration Statement on or about June 9, 2020, and will file the joint acceleration requests (the “Acceleration Requests”) in time before the requested effective time. The Company would greatly appreciate the Commission’s continuing assistance and support in meeting the proposed timetable for the offering.

Comments in Letter Dated June 4, 2020

Selected Consolidated Financial and Operating Data

Selected Operating Data, page 91

In response to the Staff’s comment, the Company has revised the disclosure on pages 16 and 91 of the Revised Registration Statement.

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 92

In response to the Staff’s comment, the Company has revised the disclosure on page 96 of the Revised Registration Statement.

Key Factors Affecting Our Results of Operations, page 93

U.S. Securities and Exchange Commission

June 5, 2020

Page 3

In response to the Staff’s comment, the Company has revised the disclosure on pages 35 and 95 of the Revised Registration Statement.

Gross profit and margin, page 102

In response to the Staff’s comment, the Company has revised the disclosure on pages 102 and 103 of the Revised Registration Statement.

Results of Operation

Cost of Revenues, page 104

The Company respectfully advises the Staff that, assuming the Company procured the same amount of data in 2019 as in 2018, the cost savings resulting from lower unit cost would have been USD14.6 million. However, the Company respectfully advises the Staff that it is not able to quantitatively isolate the impact of better prices for data procurement from impact of improved data operation efficiency. First, in some cases, the MNOs offer unlimited data supplies for fixed prices, which means that the more data consumed, the lower the cost of data on a per unit basis. The Company obtained better fixed prices in some cases in 2019, while the Company’s cloud SIM technology and its proprietary algorithms also increase the data utilization efficiency for such data supplies. Second, the Company has been constantly improving its cloud SIM platform, which can dynamically and intelligently select those SIM cards with better prices and higher operation efficiency. This naturally results in preferences towards data procured with better prices and simultaneous operation efficiency improvement. See “Business—Our Cloud SIM Technology and Architecture—Cloud SIM Architecture—uCloudlink Cloud SIM Platform—Dispatcher of Mobile Data Connectivity Services.”

The Company expects additional cost savings in the future that are largely in line with the industry trend. In response to the Staff’s comment, the Company has revised the disclosure on page 104 of the Revised Registration Statement. In addition, the Company respectfully advises the Staff that the impact on cost of services resulting from the changes in services provided in 2019 was not significant.

*        *        *

If you have any questions regarding the Revised Registration Statement, please contact the undersigned by phone at +852 3740-4863 or via e-mail at julie.gao@skadden.com.

Enclosures

Zhiping Peng, Chairman of the Board of Directors, UCLOUDLINK GROUP INC.

Yimeng Shi, Chief Financial Officer, UCLOUDLINK GROUP INC.

Shu Du, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP

Ricky W Shin, Partner, PricewaterhouseCoopers Zhong Tian LLP

David Zhang, Esq., Partner, Kirkland & Ellis LLP

Steve Lin, Esq., Partner, Kirkland & Ellis LLP