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                            January 4, 2024

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

                                                        Re: Elate Group, Inc.
                                                            Amendment No. 19 to
Registration Statement on Form S-1
                                                            Filed December 27,
2023
                                                            File No. 333-264073

       Dear Kevin Britt:

            We have reviewed your amended registration statement and have the
following
       comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a 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 letter, we may have additional comments.

       Amendment No. 19 to Registration Statement on Form S-1

       Prospectus Summary, page 1

   1.                                                   Where applicable
throughout your filing, please revise to provide updated disclosures for
                                                        your most recently
completed fiscal year. As an example only, we note your disclosure on
                                                        page 4 that customer
cancellations have had a negative impact on revenue growth during
                                                        2021 and 2022. Revise
to provide updated disclosures for the recently completed fiscal
                                                        year, December 31,
2023.
   2.                                                   Please consider
updating your disclosures in regard to COVID-19.
 Kevin Britt
FirstName  LastNameKevin  Britt
Elate Group, Inc.
Comapany
January     NameElate Group, Inc.
        4, 2024
January
Page  2 4, 2024 Page 2
FirstName LastName
Capitalization, page 39

3.       Please detail how you determined As Adjusted cash and additional paid
in capital
         presented in the table as we are unable to reconcile the changes
between the Actual and
         As Adjusted balances using offering information presented elsewhere
within the
         registration statement.
Dilution, page 40

4.       We note that the $4,517,983 of As adjusted net tangible book value per
share after the
         offering as disclosed in your dilution table differs from the
$4,467,983 As Adjusted total
         stockholders' equity as disclosed in your capitalization table. Please
reconcile these two
         amounts and revise your disclosure as necessary.
Executive Compensation, page 73

5.       Please revise to provide executive compensation disclosures for the
most recently
         completed fiscal year ending December 31, 2023. Refer to Item 11(l) of
Form S-1 and
         Item 402 of Regulation S-K.
       Please contact Jenifer Gallagher at 202-551-3706 or John Cannarella at
202-551-3337 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Cheryl Brown at 202-551-3905 or Lauren Nguyen at 202-551-3642 with any
other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Energy
& Transportation
cc:      Peter Hogan, Esq.