SecProbe.io

March 27, 2020
In Keuk Kim
Chief Executive Officer
DoubleDown Interactive Co., Ltd.
13F, Gangnam Finance Center
152, Teheran-ro Gangnam-gu
Seoul 06236, Republic of Korea
Re:DoubleDown Interactive Co., Ltd.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted March 12, 2020
CIK No. 0001799567
Dear Mr. Kim:
            We have reviewed your amended draft registration statement 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.  Unless otherwise noted, where prior comments are referred to they refer to our letter
dated February 18, 2020.
Amendment No. 1 to Draft Registration Statement on Form F-1
Risk Factors
Risks related to our relationship with DoubleU Games, page 28
1.We note that you have removed the risk factor related to your status as a controlled
company.  Please include this risk factor in your filing as your status as a controlled
company presents risks that are separate and apart from your status as a foreign private
issuer.

 FirstName LastNameIn Keuk Kim
 Comapany NameDoubleDown Interactive Co., Ltd.
 March 27, 2020 Page 2
 FirstName LastName
In Keuk Kim
DoubleDown Interactive Co., Ltd.
March 27, 2020
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Management's Discussion and Analysis of Financial Condition and Results of Operations
Our business, page 44
2.We note in your filing you have a declining number of players year over year.
Additionally, you derive a significant portion of your revenues from a small number of
high-paying players.  Please discuss your vulnerability to a near-term severe impact
arising from the disruption of the economy by the COVID-19 pandemic which could
affect the discretionary spending behavior of such players and thus, your revenues.  In
addition, disclose other material known or reasonably likely effects of and the types of
risks presented by COVID-19 on your financial position, results of operations, accounting
judgments and estimates and timeliness of your financial reporting.  Refer to ASC 275-10-
50-16 and CF Disclosure Guidance Topic No. 9: Coronavirus (COVID-19)
at https://www.sec.gov/corpfin/coronavirus-covid-19.
Our marketing efficiency, page 46
3.Please revise to clarify your new computation for average payback period that replaces
CPI.  We note it measures time by days for 3rd party costs to be paid back, but it uses
"cumulative revenue generated by all of the players in a given install period." If your
use of  "all players" includes organic and paid channel revenues to measure payback
periods, tell us why it is appropriate to include organic revenues unrelated to the
marketing partners fees.
Other key performance indicators and non-GAAP metrics and trends, page 47
4.We note your responses to comments 11 and 12.  Please balance your disclosure to
indicate how growth in your subscription revenue, if at all, contributed towards your total
revenue growth, ARPDAU, and average monthly revenue per user.

Furthermore, you disclose your mobile penetration represents the percentage of revenue
sourced from the Google, Apple and Amazon platforms but do not include Facebook. Tell
us why and disclose other platform revenue sources, amounts and percentages. Tell us and
disclose what comprises the balance of your revenue penetration for the periods, both
online or mobile. Also disclose whether the high paying players are predominantly mobile
or online players. To the degree there are any material trends among the individual
platform sources, mobile versus online  or high-paying players please revise your MD&A
accordingly. We refer you to Item 5.D of Form 20-F.

5.We note your response to prior comment 5.  You disclose that monetization of active
players is a key factor affecting your financial performance.  You indicate that this
monetization comes from players’ purchases of in-game virtual chips, which is how you
generate substantially all of your revenue.  You further disclose that the proportion of
revenue from high-paying players (those who spend more than $500 per month) has been
gradually rising in recent years.  Please tell us whether you use any metrics to monitor

 FirstName LastNameIn Keuk Kim
 Comapany NameDoubleDown Interactive Co., Ltd.
 March 27, 2020 Page 3
 FirstName LastName
In Keuk Kim
DoubleDown Interactive Co., Ltd.
March 27, 2020
Page 3
your revenue concentration and the impact of high-paying customers on your financial
performance, such as the percentage of revenue derived from high-paying players, number
of high-paying players as a percentage of paying players or average revenue per high-
paying player.  If so, please provide a discussion of these metrics or other related metrics
and any material trends.  We refer you to Item 5.D of Form 20-F.
Critical accounting policies and estimates
Recent accounting guidance adopted, page 61
6.Please disclose to state, if true, whether the conversion feature of the 2.5% convertible
bonds and the May 2017 warrants contain a down round provision.  If so, please further
disclose as follows:
•how you concluded whether the conversion feature or the warrants met the scope
exception in ASC 815-40 for  classification in stockholders' equity;
•whether either instrument contains terms or features other than the down round
feature that would cause liability classification on the basis of  the guidance in Topic
480 or Subtopic 815-40;
•how you evaluated the 2.5% convertible bonds under accounting guidance for debt
with conversion and other options under ASC 470-20;
•how a down round feature in the warrants  will impact the calculation of basic EPS
when triggered.

Note 2: Significant accounting policies
Revenue Recognition, page F-10
7.We note your response to prior comment 21.  You recognize virtual chip or currency
revenues when control transfers upon consumption of this currency.  Please explain and
disclose further the basis for your determination that player purchase of virtual currency
determines consumption of the currency and thereby affects revenue recognition.  In this
regard, address the assumptions used in estimating virtual currency consumption based on
your analysis of customers' historical play behavior, purchase behavior, and the amount of
virtual currency outstanding.

You disclose on page 60 you estimate the outstanding purchased virtual currency at period
end because you are unable to distinguish between the consumption of purchased versus
free currency.  Tell us and disclose the assumptions used to estimate this amount, how you
considered free currency/chips obtained during game play and through player actions on
social media outside of gameplay, as well as forfeitures, and explain the impact of any
uncertainties.  Revise to disclose this in your financial statement revenue recognition
note.

 FirstName LastNameIn Keuk Kim
 Comapany NameDoubleDown Interactive Co., Ltd.
 March 27, 2020 Page 4
 FirstName LastName
In Keuk Kim
DoubleDown Interactive Co., Ltd.
March 27, 2020
Page 4
Contract assets, Contract liabilities and other disclosures, page F-11
8.We note your response to comments 21 and 23. Elsewhere in your filing, you referred to
your loyalty program subject to a third party registration. Describe the terms of the loyalty
program and the nature of incentives and rewards that players may receive.  Disclose
whether participation in the loyalty program  provides a material right that the player
would not receive otherwise, thereby giving rise to a separate performance obligation to
which a portion of the transaction price must be allocated.  Refer to ASC 606-10-55-41
& 42.
Principal-agent considerations, page F-11
9.We note in your response to comment 22 that the platform providers have no rights to
control how the company defines its pricing. You disclose on page 77 that your platform
providers have the "ability to make unilateral changes to their platforms, their terms of
service, the amounts of or method by which  players obtain content and make payments,
how they are paid, and any other aspect of their platforms and services." Please clarify the
disclosure regarding your platform providers' inability to change your pricing. To the
extent your arrangements with Apple, Facebook and Google allow them to offer
incentives, discounts or otherwise change the price defined by you for virtual chips, tell us
whether you know the actual amount paid by your players and how that impacts the
amount you record as revenue.

Regarding your  arrangement with Facebook, please provide us your analysis as to
whether you have control or visibility over the issuance of extra chips  (up to 9 million
chips each year) in the Daily Wheel spin of each player logged onto Facebook when such
player's Facebook friends also play DoubleDown Casino. Clarify whether the invitations
to friends through the Facebook platform results in greater fees retained by Facebook.
Refer to the benefits of connecting through Facebook in DoubleDown Casino
at https://doubledowncasino1.zendesk.com/hc/en-us/articles/201395160-Benefits-of-
connecting-through-Facebook-in-DoubleDown-Casino.
Note 4: Debt, page F-16
10.We note your response to comments 24 and 26 and your revised disclosures.  With respect
to the 2.5% convertible bonds and the May 2017 warrants, please clarify and state if true
whether "certain adjustments for anti-dilution protection" constitute a down round
provision or whether they may be deemed standard anti-dilution protection..

Further clarify how your assessment of such provisions  could be affected by the
probability (or remote likelihood) of price adjustment(s) or by such adjustments being
under your control.  Refer to your basis in the accounting literature.

 FirstName LastNameIn Keuk Kim
 Comapany NameDoubleDown Interactive Co., Ltd.
 March 27, 2020 Page 5
 FirstName LastName
In Keuk Kim
DoubleDown Interactive Co., Ltd.
March 27, 2020
Page 5
            You may contact Kathryn Jacobson, Senior Staff Accountant, at (202) 551-3365 or Craig
Wilson, Senior Advisor, at (202) 551-3226 if you have questions regarding comments on the
financial statements and related matters.  Please contact Jeff Kauten, Staff Attorney, at (202)
551-3447 or Kathleen Krebs, Special Counsel, at (202) 551-3350 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Barbara A. Jones, Esq.