SIMPSON THACHER & BARTLETT

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HONG KONG

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+852 2514-7660	dfertig@stblaw.com

December 31, 2019

CONFIDENTIAL AND VIA EDGAR AND HAND DELIVERY

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention:	Andrew Blume, Staff Accountant
	Jennifer Thompson, Accounting Branch Chief

Re:	Alibaba Group Holding Limited Form 20-F for the Fiscal Year Ended March 31, 2019 Filed June 5, 2019 File No. 1-36614

Ladies and Gentlemen:

On behalf of our client Alibaba Group Holding Limited (the “Company”), we are submitting this letter in response to your follow-up correspondence dated December 18, 2019 (the “December 18 Letter”) concerning the above-referenced annual report on Form 20-F that the Company filed with the Commission on June 5, 2019.

In the December 18 Letter, you requested that the Company respond to the Staff’s comments within 10 business days or advise the Staff when the Company will respond. The Company respectfully advises the Staff that it continues to work on its responses and that it will require additional time in order to respond fully to your letter.

The Company is therefore requesting an extension until January 17, 2020 and expects to respond no later than that date and will endeavor to respond earlier if possible.

* * *

daniel fertig adam C. furber MAKIKO HARUNARI Ian C. Ho anthony d. king celia c.l. lam chris k.h. lin jin hyuk park kathryn king sudol christopher k.s. wong

RESIDENT PARTNERS

SIMPSON THACHER & BARTLETT, HONG KONG IS AN AFFILIATE OF SIMPSON THACHER & BARTLETT LLP WITH OFFICES IN:

NEW YORK BEIJING HOUSTON LONDON LOS ANGELES PALO ALTO SÃO PAULO TOKYO WASHINGTON, D.C.

In the meantime, please do not hesitate to contact me at +852-2514-7660 (work) or dfertig@stblaw.com (email).

	Very truly yours,

	/s/ Daniel Fertig

	Daniel Fertig

cc:	Daniel Yong Zhang, Chief Executive Officer
	Maggie Wei Wu, Chief Financial Officer
	Timothy A. Steinert, General Counsel and Secretary
	Alibaba Group Holding Limited