Exhibit 5.2

北京市朝阳区建国门外大街2号银泰中心C座2201-B室，邮编100022

联系电话：+86 10 8379 8686 工作传真：+86 10 6594 8686

Rm2201-B, 22F, Building C, Yintai Center, No.2 Jianguomenwai Avenue, Beijing China 100022

Tel：+86 10 8379 8686 Fax：+86 10 6594 8686

Date: December 16, 2019

To: Pony Group Inc.

Engineer Experiment Building, A202,

7 Gaoxin South Avenue, Nanshan District, Shenzhen,

Guangdong Province, China 518054

Re: Legal Opinion on Certain PRC Law Matters

Dear Sir/Madam:

We are qualified lawyers of the People’s Republic of China (the “PRC”, for the sole purpose of this legal Opinion, excluding the Hong Kong Special Administrative Region, the Macau Special Administrative Region and Taiwan), and as such are qualified to issue this legal opinion on the laws and regulations of the PRC (this “Opinion”).

We are acting as the PRC legal counsel for Pony Group Inc., a company incorporated under the laws of Delaware, USA(the “Company”), in connection with the Company’s registration statement on Form S-1 including all amendments or supplements thereto (the “Registration Statement”), relating to the proposed initial public offering (the “Offering”) of up to 2,500,000 ordinary shares by the Company (the “Ordinary Shares”).

As used herein, the following terms are defined as follows:

For the purpose of giving this Opinion, we have examined the Registration Statement, the originals or copies of documents provided to us by the Company and the PRC Entity and such other documents, corporate records, certificates, approvals and other instruments as we have deemed necessary or advisable for the purpose of rendering this Opinion (the “Documents”).

In our examination of the aforesaid Documents, we have assumed, without independent investigation and inquiry that:

Based upon and subject to the foregoing descriptions and assumptions, we are of the opinion that as at the date hereof:

On August 8, 2006, the PRC Ministry of Commerce, the State Assets Supervision and Administration Commission, the State Administration for Taxation, the State Administration for Industry and Commerce, the China Securities Regulatory Commission (“CSRC”) and the State Administration of Foreign Exchange jointly promulgated the Regulations on Mergers and Acquisitions of Domestic Enterprises by Foreign Investors , which became effective on September 8, 2006 and was amended on June 22, 2009 (the “M&A Rules”). The M&A Rules require among other things, that offshore special purpose vehicles formed for overseas listing purposes through acquisitions of PRC domestic companies and controlled directly or indirectly by PRC companies or individuals should obtain the approval of the CSRC prior to publicly listing their securities on an overseas stock exchange. Based on our understanding, our PRC Entity was established by means of direct investment rather than by a merger with or an acquisition of any PRC domestic companies under the M&A Rules, therefore the requirement of the M&A Rules is not applicable to the Company and the Company is not required to submit an application to CSRC for the approval of the Offering.

The statements set forth in the Registration Statement under the caption “Risk Factors”, “Business” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations”, insofar as they constitute statements of PRC tax law, are accurate in all material respects and that such statements constitute our opinion, and nothing has been omitted from such statements which would make the same misleading in any material aspects.

PRC courts may recognize and enforce foreign judgments in accordance with the requirements of PRC Civil Procedural Law based either on treaties between China and the country where the judgment is made or on reciprocity between jurisdictions. China does not have any treaties or other form of reciprocity with the United States that provide for the reciprocal recognition and enforcement of foreign judgments. As a result, it is uncertain whether and on what basis a PRC court would recognize and enforce a judgment rendered by a court in the United States.

All statements set forth in the Registration Statement under the captions “Prospectus Summary”, “Risk Factors”, “Use of Proceeds”, “Management’s Discussion and Analysis of Financial Condition and Results of Operations” and “Business”, in each case insofar as such statements describe or summarize PRC legal or regulatory matters, or documents, agreements or proceedings governed by PRC Laws, are true and accurate in all material aspects, and are fairly disclosed and correctly set forth therein, and nothing has been omitted from such statements which would make the same misleading in all material aspects.

We hereby consent to the quotation or summarization of this Opinion in, and the filing hereof, as Exhibit 5.2 to the Registration Statement.

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