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November 10, 2022
Karl Kan Zhang
Chairman of the Board and Chief Technology Officer
CooTek(Cayman)Inc.
9-11F, T2, No.16 Lane 399 Xinlong Road, Minhang District
Shanghai, 201101
People's Republic of China
Re:CooTek(Cayman)Inc.
Form 20-F for the Fiscal Year Ended December 31, 2021
Filed April 29, 2022
File No. 001-38665
Dear Karl Kan Zhang:
            We have reviewed your October 27, 2022 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our September
19, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Financial Information Related to the VIE's, page 8
1.We note your response to our prior comment 5.  The line item "Equity in (loss)
income from subsidiaries and share of loss from VIEs" in your proposed revised
disclosures appears to imply an equity relationship exists between the WFOE and the
VIEs.  Please revise to present the share of (loss)/income from VIEs in a separate line item
from the equity in (loss) income from subsidiaries.  Also, we note that the amounts
included in this line item for each column, as adjusted for the amounts in the eliminations
column, do not foot across to the consolidated total in your current proposed disclosures in
Appendix I.  Please ensure this is corrected when you revise the consolidating income
statement to address this comment.

 FirstName LastNameKarl Kan Zhang
 Comapany NameCooTek(Cayman)Inc.
 November 10, 2022 Page 2
 FirstName LastName
Karl Kan Zhang
CooTek(Cayman)Inc.
November 10, 2022
Page 2
Item 15. Controls and Procedures, page 150
2.Please amend the filing to disclose management's assessment of your internal control over
financial reporting (ICFR) as effective as noted in response to comment 12 in your letter
dated September 2, 2022.  Also, ensure you incorporate all proposed changes provided in
each of your previous response letters, including the comments herein, in your amended
Form 20-F when filed.
            You may contact Megan Akst, Senior Staff Accountant at 202-551-3407 or Kathleen
Collins, Accounting Branch Chief at 202-551-3499 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Haiping Li