TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo March 2, 2021 Zhang Jianbo Chief Executive Officer Elite Education Group International Ltd 1209 N. University Blvd. Middletown, OH 45042 Re: Elite Education Group International Ltd Amendment No. 3 to Registration Statement on Form F-1 Filed February 24, 2021 File No. 333-251342 Dear Mr. Jianbo: We have reviewed your amended registration statement and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our 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 comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our February 23, 2021 letter. Amendment No. 3 to Registration Statement on Form F-1 Exhibit 8.2 1. Please revise Section 3 of the opinion to state that the statements under the heading "British Virgin Islands Taxation" constitute the opinion of counsel, rather than a fair and accurate summary. Refer to Section III.C.2 of Staff Legal Bulletin No. 19. In addition, please delete the reference to page 72, as the relevant statements do not appear on such page and the page numbering of the printed prospectus could change going forward. Finally, please revise Section 1 to clarify that you reviewed all documents necessary for the purpose of rendering the opinion rather than only the documents identified, and delete Section 2(f) accordingly. Zhang Jianbo Elite Education Group International Ltd March 2, 2021 Page 2 You may contact Tony Watson at (202) 551-3318 or Doug Jones at (202) 551-3309 if you have questions regarding comments on the financial statements and related matters. Please contact Cara Wirth at (202) 551-7127 or Lilyanna Peyser at (202) 551-3222 with any other questions. Sincerely, FirstName LastNameZhang Jianbo Division of Corporation Finance Comapany NameElite Education Group International Ltd Office of Trade & Services March 2, 2021 Page 2 cc: F. Alec Orudjev, Esq. FirstName LastName