September 19, 2024

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

       Re: NewGenIvf Group Ltd
           Registration Statement on Form F-1
           Filed September 6, 2024
           File No. 333-281964
Dear Wing Fung Alfred Siu:

     We have conducted a limited review of your 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.

Registration Statement on Form F-1
Prospectus Summary, page 1

1.     We note your Form 6-K, filed June 3, 2024, discloses that you have
entered into a non-
       binding term sheet for a potential reverse merger with COVIRIX Medical
Pty Ltd. Please
       update your disclosure here and where appropriate to discuss the status
of this potential
       merger. Additionally, please tell us what consideration you gave to
including financial
       statements of COVIRIX Medical Pty Ltd under Rule 3-05 of Regulation S-X
and pro
       forma financial statements under Article 11 of Regulation S-X.
Risk Factors, page 20

2.     We note that you did not timely file your Form 20-F for the year ended
December 31,
       2023. Please include a risk factor to disclose that you did not timely
file the report and
       that you may not be able to timely file similar reports in the future.
 September 19, 2024
Page 2
Plan of Distribution, page 62

3.     We note your disclosure on page 62 that your selling shareholders may
sell their securities
       in transactions through underwriters. Please confirm your understanding
that the retention
       by a selling shareholder of an underwriter would constitute a material
change to your plan
       of distribution requiring a post-effective amendment. Refer to your
undertaking provided
       pursuant to Item 512(a)(1)(iii) of Regulation S-K.
Incorporation By Reference, page 74

4.     It appears that you do not meet the eligibility requirements to be able
to incorporate by
       reference. Please note that in order to be able to incorporate by
reference, registrants,
       including their predecessors, must not have been a blank check company
as defined in
       Rule 419(a)(2) during the past three years. Refer to General Instruction
VI.D of Form F-1.
       Please revise or advise.
General

5.     We note that in your Form 6-K, filed on May 28, 2024, you disclose that
you received a
       notice of non-compliance with the Nasdaq requirements pertaining to the
minimum bid
       price for listed stock pursuant to its rules for continued listing.
Please revise the Summary
       to describe this notice and include disclosure in the Risk Factor
section describing the
       risks related to this notice and the risks of a potential delisting.


        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Robert Augustin at 202-551-8483 or Margaret Sawicki at
202-551-7153
with any other questions.



                                                             Sincerely,

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