Simpson Thacher & Bartlett
icbc tower, 35th floor 3 garden road, central hong kong
telephone: +852-2514-7600 facsimile: +852-2869-7694
Direct Dial Number +852-2514-7660	E-mail Address dfertig@stblaw.com

December 23, 2022

VIA EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

00 F Street, N.E.

Washington, D.C. 20549

Attention: Blaise Rhodes

Linda Cvrkel

Nicholas Nalbantian

Donald Field

Re: Alibaba Group Holding Ltd

Form 20-F for the Fiscal Year Ended March 31, 2022

Filed July 26, 2022

File No. 001-36614

Ladies and Gentlemen:

We are submitting this letter in response to your correspondence dated December 12, 2022 (the “December 12 Letter”) concerning the above-referenced annual report on Form 20-F that Alibaba Group Holding Limited (the “Company”) filed with the Commission on July 26, 2022.

In the December 12 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 anticipates that it will require additional time in order to respond fully to your letter.

michael j.c.M. ceulen marjory j. ding daniel fertig adam C. furber YI GAO MAKIKO HARUNARI Ian C. Ho JONATHAN HWANG anthony d. king jin hYUK park 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	Brussels	Houston	LONDON	Los Angeles	Palo Alto	SÃO PAULO	TOKYO	Washington, D.C.

Simpson Thacher & Bartlett
December 23, 2022	-2-

The Company is therefore requesting an extension until January 11, 2023 (10 business days from the date of this request, taking into account the federal public holidays on December 26, 2022 and January 2, 2023) and expects to respond by that date.

*      *     *     *

If you have any question regarding the responses contained in this letter, please do not hesitate to contact me at +852-2514-7660 or dfertig@stblaw.com. 

Very truly yours,

/s/ Daniel Fertig

Daniel Fertig

cc: Daniel Yong Zhang, Chief Executive Officer

Toby Hong Xu, Chief Financial Officer

Sara Siying Yu, General Counsel

Alibaba Group Holding Limited