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                              December 5, 2022

       Kevin Britt
       Chief Executive Officer
       Elate Group, Inc.
       305 Broadway, Floor 7
       New York, NY 10007

                                                        Re: Elate Group, Inc.
                                                            Amendment No. 11 to
Registration Statement on Form S-1
                                                            Filed November 28,
2022
                                                            File No. 333-264073

       Dear Kevin Britt:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
November 7, 2022 letter.

       Amendment No 11 to Registration Statement on Form S-1

       Capitalization, page 42

   1.                                                   We note the revisions
you have made to the capitalization table in response to prior
                                                        comment 4; however, it
appears you have not adjusted Additional paid in capital for the
                                                        total estimated
offering expenses to be incurred but rather only for the amount that
                                                        was deferred as of
September 30, 2022. In addition, you should reduce the Cash and cash
                                                        equivalents account
balance for the estimated offering expenses which were unpaid and
                                                        not yet reflected in
the Deferred offering costs account balance as of September 30, 2022.
                                                        Please further revise
the "as adjusted" column of your capitalization table to address these
                                                        items.
 Kevin Britt
Elate Group, Inc.
December 5, 2022
Page 2

        You may contact Jenifer Gallagher, Staff Accountant, at (202) 551-3706
or John
Cannarella, Staff Accountant, at (202) 551-3337 if you have questions regarding
comments on
the financial statements and related matters. Please contact Cheryl Brown,
Staff Attorney, at
(202) 551-3905 or Loan Lauren Nguyen, Legal Branch Chief, at (202) 551-3642
with any other
questions.



                                                          Sincerely,
FirstName LastNameKevin Britt
                                                          Division of
Corporation Finance
Comapany NameElate Group, Inc.
                                                          Office of Energy &
Transportation
December 5, 2022 Page 2
cc:       Peter Hogan, Esq.
FirstName LastName