SecProbe.io

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Mail Stop 4561

      							September 8, 2005

Via U.S. Mail and Fax 011-82-2-2057-2568
Mr. Won-Seon Kim
Chief Financial Officer
Webzen Inc.
Daelim Acrotel Building, 6th Floor
467-6 Dogok-dong, Kangnam-ku
Seoul, Korea 135-971

	RE:	Webzen Inc.
      Form 20-F for the fiscal year ended December 31, 2004
		Filed June 29, 2005
		File No. 0-50476

Dear Mr. Kim:

      We have reviewed the above referenced filing and have the
following comments.  Where indicated, we think you should revise
your
document in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Item 6. Directors, Senior Management and Employees

6.C. Board Practices

Independent Directors, page 36

1. Tell us what occurred on July 31, 2005 regarding the exemption
granted by NASDAQ.  Specifically clarify whether you were in
compliance at that time, whether the exemption was extended, or
whether some penalty was assessed.

6.D. Employees, page 39

2. Clarify to us whether the payments to the National Pension
Corporation are in addition to the liability for severance
benefits
under the Korean Labor Standard Act or whether these payments
represent a portion of the severance payments included in the
table
on page F-16.

Note 10. Stockholders` Equity

Retained Earnings, page F-19

3. Please clarify to us your appropriations of retained earnings.
Specifically address:
* The reason why there does not appear to be a legal reserve, as
discussed, in your table of retained earnings.
* Why there is still an appropriation for business rationalization
when your disclosure indicates that it is no longer required.
* How the reserve for small and medium size enterprise is
determined.

Note 12. Stock Purchase Option Plan, page F-20

4. The original grant of stock options on July 10, 2002 does not
seem
to be included in the Consolidated Statements of Changes in
Stockholders` Equity.  Please tell us how the original grant was
accounted for including the deferred compensation relating to the
grant.  Also, tell us how you have accounted for the subsequent
cancellations/forfeitures of options.

5. Your disclosure on page F-21 indicates that the fair value for
each option was estimated at the balance sheet date.  Explain to
us
why such valuation was not estimated as of the date of grant.

Note 13.  Income Taxes, page F-22

6. Clarify to us whether the income tax charges on your equity
method
investments represent taxes charged to those entites or taxes
charged
to you relating to your investment in those entities.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that they
have
provided all information required under the Securities Exchange
Act
of 1934 and that they have provided all information investors
require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact William Demarest, Staff Accountant, at (202)
551-3432 or me at (202) 551-3486 with any questions.

							Sincerely,

							Daniel L. Gordon
							Branch Chief

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Mr. Won-Seon Kim
Webzen Inc.
September 8, 2005
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