SecProbe.io

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      September 26, 2005

Via U.S. Mail

David Woong-Jin Yoon
Chief Executive Officer
GRAVITY Co., Ltd.
Shingu Building
620-2 Shinsa-dong, Gangnam-gu
Seoul 135-894 Korea

RE:		GRAVITY Co. Ltd.
		20-F for the Fiscal Year Ended December 31, 2004
		File No. 000-51138

Dear Mr. Yoon:

      We have limited our review of your Form 20-F for the fiscal
year ended December 31, 2004 to disclosures relating to your
contacts
with countries that have been identified as state sponsors of
terrorism, and will make no further review of the Form 20-F.  Our
review with respect to this issue does not preclude further review
by
the Assistant Director group with respect to other issues.  At
this
juncture, we are asking you to provide us with supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. After
reviewing
this information, we may or may not 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
filings.
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.

General -

We note that on page 31 of your 20-F you state that you are
planning
to conduct "closed beta testing" of Ragnarok Online in 15
countries,
including Syria and Iran.  In light of the fact that Syria and
Iran
have been identified by the U.S. State Department as state
sponsors
of terrorism and are subject to economic sanctions administered by
the U.S. Treasury Department`s Office of Foreign Assets Control
(OFAC), please describe for us the extent and nature of your past,
current, and  anticipated contacts with Syria and Iran; advise us
of
the materiality to you of your contacts with Syria and Iran; and
advise us of your view as to whether those contacts constitute,
either individually or in the aggregate, a material investment
risk
for your security holders.  In preparing your response please
consider that evaluations of materiality should not be based
solely
on quantitative factors, but should include consideration of all
factors that a reasonable investor would deem important in making
an
investment decision, including the potential impact of corporate
activities upon a company`s reputation and share value.  In this
regard, we note that Arizona and Louisiana have adopted
legislation
requiring divestment from, or reporting of interests in, companies
that do business with countries designated as state sponsors of
terrorism.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the 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 the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, 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 filings;

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

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Karen Garnett
		Assistant Director
		Division of Corporation Finance

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