SecProbe.io

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                                                                October 28, 2005

Office of Global Security Risk
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Mr. Jack Guggenheim

VIA EDGAR

                                GRAVITY CO., LTD.
     ANNUAL REPORT ON FORM 20-F FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004
                               FILE NO. 000-51138

Dear Mr. Guggenheim:

     Reference is made to the letter dated September 26, 2005 (the "Request
Letter") from Ms. Cecilia D. Blye of the Office of Global Security Risk of the
U.S. Securities and Exchange Commission (the "SEC"). The Request Letter
requests, in connection with the SEC's review of the annual report on Form 20-F
for the fiscal year ended December 31, 2004 for Gravity Co., Ltd. (the
"Company"), that the Company respond to the SEC's comment regarding the
Company's contacts with countries that have been identified as state sponsors of
terrorism.

     In this regard, the Company acknowledges that:

     -    the Company is responsible for the adequacy and accuracy of the
          disclosure in the filing;

     -    the Staff comments or changes to disclosure in response to Staff
          comments do not foreclose the SEC 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 SEC or any person under the federal
          securities laws of the United States.

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     The comments of the Staff are set forth below, and the responses from the
Company are set forth below the Staff comments.

SEC Staff Comment:

     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 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.

The Company's Response:

(i)  The extent and nature of the Company's past, current and anticipated
     contacts with Syria and Iran.

     The Company has no assets located in Syria and Iran, has not provided any
goods or services to any person in Syria or Iran and has not maintained any
place of business in those two countries.

     On May 2, 2005, the Company entered into a licensing agreement (the
"Licensing Agreement") with Sento Enterprises Limited, a corporation organized
and existing under the laws of the Republic of Cyprus ("Sento"), pursuant to
which Sento will, in consultation with the Company, handle marketing,
operations, billing and customer service for Ragnarok Online to online game
users in the Middle East, including those in Bahrain, Egypt, Iran, Iraq, Israel,
Jordan, Kuwait, Lebanon, Oman, Qatar, Saudi Arabia, Syria, the United Arab
Emirates and Yemen. The term of the Licensing Agreement is for three years from
when the Ragnarok Online is first offered commercially to online game users in
the Middle East. The Company and Sento have not yet begun offering Ragnarok
Online to online game users in the Middle East and the two companies are still
in the process of preparing for the closed beta testing of Ragnarok Online.

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     The Company has agreed in principle with Sento to amend the Licensing
Agreement such that Syria and Iran will be removed from the countries to be
covered under the scope of the Licensing Agreement. The Company plans to enter
into such amendment on or about November 4, 2005.

(ii)  The materiality to the Company of the Company's contacts with Syria and
      Iran.

     As mentioned above, the Company will enter into an amendment to the
Licensing Agreement to remove Syria and Iran from the countries covered under
the scope of the Licensing Agreement. As a result, the contemplated commercial
launch of Ragnarok Online in the Middle East will not result in the Company
having any contact with either Syria or Iran.

(iii) The Company's views as to whether those contacts constitute, either
      individually or in the aggregate, a material investment risk for the
      Company's security holders.

     The Company did not have, and currently does not have, any contact with
either Syria or Iran. Moreover, as the Licensing Agreement will be amended to
exclude Syria and Iran, the Company does not expect to have any contact with
Syria or Iran in the future.

     For the foregoing reasons, the Company views that the Company's security
holders are not exposed to any material investment risk in connection with the
Company having any contact with a state sponsor of terrorism.

                                    * * * * *

     We hope that the above is responsive to the SEC's comments. Please do not
hesitate to contact me at +82 (2) 3485 1002 (Fax: +82 (2) 3442 7097) should you
have any questions or comments. Also, we would appreciate you copying Mark J.
Lee and David Cho of Debevoise & Plimpton LLP (Tel: 852-2160-9800; Fax:
212-521-8950 (U.S. fax number)) when you send any written correspondence to us
to ensure that we will be able to promptly respond to any comments or requests
from the SEC.

                                            Very truly yours,

                                            /s/ John C. Chung

                                            John C. Chung
                                            General Counsel

cc: Ms. Celicia D. Blye, Chief of the Office of Global Security Risk

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