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Correspondence 0001140361-23-057003 from Sea Ltd (SE)

Sea Ltd
Date: Dec. 8, 2023 · CIK: 0001703399 · Accession: 0001140361-23-057003

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File numbers found in text: 001-38237

Referenced dates: December 5, 2023

Date
December 8, 2023
Author
/s/ Tony Tianyu Hou
Form
CORRESP
Company
Sea Ltd

Letter

Division of Corporate Finance Office of Trade & Services Sea Limited Form 20-F for the Fiscal Year Ended December 31, 2022 Filed April 6, 2023 File No. 001-38237

Dear Ms. Geddes and Mr. Jones:

Sea Limited (the “Company”) confirms that it has received the letter dated December 5, 2023 (the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission with respect to the above-referenced Form 20-F. The Company respectfully requests an extension and expects to respond to the comments in the Comment Letter on or before Friday, January 12, 2024.

Please contact Dwight S. Yoo at (212) 735-2573 or Dwight.Yoo@skadden.com if the Staff has any questions or requires additional information.

Very truly yours,
/s/ Tony Tianyu Hou

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CORRESP
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                December 8, 2023

      BY EDGAR

      Division of Corporate Finance

      Office of Trade & Services

      U.S. Securities and Exchange Commission

      100 F Street, N.E.

      Washington, DC 20549

                Attn:

                Amy Geddes

      Doug Jones

                  Re:

                    Sea Limited

      Form 20-F for the Fiscal Year Ended December 31, 2022

      Filed April 6, 2023

      File No. 001-38237

      Dear Ms. Geddes and Mr. Jones:

      Sea Limited (the “Company”) confirms that it has received the letter
        dated December 5, 2023 (the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange
        Commission with respect to the above-referenced Form 20-F. The Company respectfully requests an extension and expects to respond to the comments in the Comment Letter on or before Friday, January 12, 2024.

      Please contact Dwight S. Yoo at (212) 735-2573 or Dwight.Yoo@skadden.com if the Staff has any questions or requires additional information.

                Very truly yours,

                /s/ Tony Tianyu Hou

                  cc:

                Yanjun Wang, Sea Limited

                  Dwight S. Yoo, Skadden, Arps, Slate, Meagher & Flom LLP