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                             November 10, 2021

       Sze Hon, Johnson Chen
       Chief Executive Officer
       Magic Empire Global Limited
       3/F, 8 Wyndham Street
       Central, Hong Kong

                                                        Re: Magic Empire Global
Limited
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted October
8, 2021
                                                            CIK No. 0001881472

       Dear Mr. Chen:

             We have reviewed your amended draft registration statement and
have the following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amended Draft Registration Statement submitted October 8, 2021

       Cover Page

   1.                                                   Refer to your response
to comment 1. Please revise the cover page to specify in the bullet
                                                        points that
governmental actions could "significantly limit or completely hinder" your
                                                        ability to continue
operations. and remove the sentence beginning "However, as we have
                                                        no subsidiary, VIE
structure . . ." in the seventh paragraph.
       Corporate History and Structure, page 3

   2.                                                   Refer to your response
to comment 11. Please revise your cover page to indicate that
                                                        following this offering
only 25% of your shares will be held by public shareholders.
 Sze Hon, Johnson Chen
Magic Empire Global Limited
November 10, 2021
Page 2
Recent Regulatory Developments in the PRC, page 6

3.     Refer to your response to comment 3. Please specify in the summary and
in your risk
       factors that the enforcement of laws and that rules and regulations in
China can change
       quickly with little advance notice, therefore, your assertions and
beliefs of the risks
       imposed by the Chinese legal and regulatory system cannot be certain.
Other Corporate Governance matters, page 86

4.     Refer to your response to comment 9. Please revise this section, and
make corresponding
       changes to the Cover Page and the Summary explicitly stating that even
if you are not
       considered a "controlled company" under Nasdaq corporate governance
rules, your
       directors, officers and principal shareholders holding [63.02%] or more
of your shares and
       will be able to control its management and affairs.
        You may contact Rolf Sundwall at (202) 551-3105 or Mark Brunhofer at
(202) 551-
3638 if you have questions regarding the financial statements and related
matters. Please contact
Eric Envall at (202) 551-3234 or J. Nolan McWilliams at (202) 551-3217 with any
other
questions.



                                                            Sincerely,
FirstName LastNameSze Hon, Johnson Chen
                                                            Division of
Corporation Finance
Comapany NameMagic Empire Global Limited
                                                            Office of Finance
November 10, 2021 Page 2
cc:       Lawrence S. Venick, Esq.
FirstName LastName