October 7, 2024

Wing Fung Alfred Siu
Chief Executive Officer
NewGenIvf Group Ltd
1/F, Pier 2, Central
Hong Kong, 999077

       Re: NewGenIvf Group Ltd
           Amendment No. 1 to Registration Statement on Form F-1
           Filed September 30, 2024
           File No. 333-281964
Dear Wing Fung Alfred Siu:

     We have reviewed your amended registration statement and have the
following
comment(s).

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

        After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our September
19, 2024
letter.

Amendment No. 1 to Registration Statement on Form F-1, filed September 30, 2024
Exhibits

1.     We note the opinion filed as Exhibit 5.1 covers 13,242,781 Class A
Ordinary Shares,
       but you are registering 139,425,259 Class A Ordinary Shares. Please have
counsel
       revise its opinion to cover the correct volume of securities.
2.     We note the consent of OneStop Assurance PAC filed as Exhibit 23.2
references your
       Annual Report on Form 20-F. Please revise this consent so that OneStop
consents to
       inclusion of its report rather than incorporating by reference to the
20-F. Additionally,
       WWC, P.C. needs to consent to being named as an expert in the filing in
its consent
       filed as Exhibit 23.1. Finally, one of these auditor consents must cover
the 2021
       financials included in the filing.
 October 7, 2024
Page 2

General

3.    We note your response to prior comment 4, which we reissue in part. We
note you
      removed the Incorporation By Reference section. Please also revise to
remove all
      references to incorporating by reference, such as on page 75, and include
the sections
      that were intended to be incorporated by reference, such as Items 3.B, 6,
7 and 9.D of
      Form 20-F. We note also that your Prospectus Summary "highlights
information
      contained elsewhere in this prospectus" but most of this information does
not appear
      elsewhere given there is no Business section.
4.    We note your response to prior comment 5, which we reissue in part. We
note that
      you disclose that you received a notice of non-compliance with the Nasdaq
listing
      requirements pertaining to minimum bid price in the Risk Factors. Please
revise this
      risk factor to disclose the deadline by which you must regain compliance.
      Additionally, please also revise the Summary to describe this notice.
5.    Please provide unaudited financial statements covering at least the first
six months of
      the 2024 fiscal year or explain why such financial statements are not
required. Refer
      to Item 8.A(5) of Form 20-F.
      Please contact Robert Augustin at 202-551-8483 or Margaret Sawicki at
202-551-
7153 with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services
cc:   Darrin Ocasio