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                                                            May 2, 2025

Kit Shing Cheung
Chief Executive Officer
Thrive Capital Group Co., Ltd
Room 1109, 11/F, Tai Yau Building
No. 181 Johnston Road, Wanchai, Hong Kong

       Re: Thrive Capital Group Co., Ltd
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted April 9, 2025
           CIK No. 0002058349
Dear Kit Shing Cheung:

     We have reviewed your amended draft registration statement and have the
following
comment.

       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 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 the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our April 3, 2025 letter.

Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted April 9,
2025
Cover Page

1.     We note your revised disclosure in response to prior comment 3, as well
as your
       disclosure on page 23 that you have paid dividends to your shareholders
in the past.
       Please provide additional detail regarding these dividends, including
quantifying
       the amounts. Please make similar disclosure in your section regarding
cash transfers
       beginning on page 3. Alternatively, please confirm that payment of the
dividends did
       not occur during the time period covered by the registration statement.
 May 2, 2025
Page 2

       Please contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Cara Wirth at 202-551-7127 with any
other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services
cc:   Lawrence Venick
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