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August 15, 2023
Yao (Jessie) Liu
Chief Financial Officer
Tuya Inc.
10/F, Building A, Huace Center
Xihu District, Hangzhou City
Zhejiang, 310012
People's Republic of China
Re:Tuya Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 26, 2023
File No. 001-40210
Dear Yao (Jessie) Liu:
            We have reviewed your August 4, 2023 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
June 15, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
General
1.We note that in the responses to prior comments 5 and 6, you only provided legal analysis
regarding “significant subsidiaries.”  However, the prior comments asked for such
analysis as to all subsidiaries, whether or not “significant.” Accordingly, please provide
the same legal analysis previously requested for each subsidiary, regardless of whether
such subsidiary is categorized as “significant.”
2.Please update all figures and calculations in the response to prior comments 5 and 6 to
conform to your financial statements as of June 30, 2023.

 FirstName LastNameYao (Jessie) Liu
 Comapany NameTuya Inc.
 August 15, 2023 Page 2
 FirstName LastNameYao (Jessie) Liu
Tuya Inc.
August 15, 2023
Page 2
3.Your response to prior comment 6 about whether the Company meets the definition of an
“investment company” under section 3(a)(1)(C) of the Investment Company Act of 1940
(the “Company Act”) was not fully responsive.  Accordingly, please provide all relevant
calculations under Section 3(a)(1)(C) to support the analysis provided, identifying each
constituent part of the numerator(s) and denominator(s) and the legal basis for your
treatment of each such component under Section 3(a)(1)(C).
4.We note from the response to prior comment 6 that you treat “short-term deposits” with
maturities of one year or less as cash items in the context of the analysis under section
3(a)(1)(C) of the Company Act. Please address the following:
•Provide a detailed legal analysis of why such “short-term deposits” should be treated
as cash items for purposes of section 3(a)(1)(C) of the Company Act in light of (i) the
1982 amendments to the definition of “security” (see, e.g., Public Law 97-303, 96
Stat. 1409 (October 13, 1982) and associated Senate report) and (ii) Revisions to
Rules Regulating Money Market Funds, SEC Release Nos. 33-6882 and IC-18005
(February 20, 1991) (see, e.g., section II.B.1.c and fn. 28).
•While we note you state that the “short-term deposits” were held for working capital
purposes, explain in additional detail whether, and to what extent, the Company and
its subsidiaries have or had any investment intent with respect to the “short-term
deposits” (addressing, in appropriate detail, the factors referenced in fn. 4 and 29 of
Certain Prima Facie Investment Companies, SEC Release No. IC-10937 (Nov. 13,
1979) (“3a-1 Release”)).  In this regard, we note that the Rule 3a-1 Release states that
“[c]ertificates of deposits and time deposits typically would not be considered cash
items absent convincing evidence of no investment intent.”
•Provide a detailed explanation of the facts and circumstances surrounding the relative
increase in assets categorized as “short-term investments”,  and relative decrease in
assets categorized as “cash and cash equivalents,” in your Consolidated Balance
Sheets between December 31, 2021 and December 31, 2022.
•Recalculate all relevant calculations in the response to prior comment 5 and 6 relating
to Section 3(a)(1)(A) of the Company Act, (i) as of June 30, 2023 (as noted above)
and (ii) under the assumption that such “short-term deposits” are not cash items.
5.Without limiting the generality of the foregoing comment, please provide factual details
and a detailed legal analysis regarding whether you view the following assets of the
Company and its subsidiaries identified in response to prior comment 6 as “investment
securities” as defined under Section 3(a)(2) of the Investment Company Act:
•Account and other receivables (whether from affiliates or third parties) related to
goods sold or services rendered;
•Prepayments;
•VAT and income tax recoverables;
•Loans from the Company to Tuya Market, Tuya (HK) and the Tuya HK Subs;
•Intangible assets; and
•The contractual arrangements between Huangzhou Tuya Information Technology Co.
Ltd and Huangzhou Tuya Technology Co. Ltd. (the VIE).

 FirstName LastNameYao (Jessie) Liu
 Comapany NameTuya Inc.
 August 15, 2023 Page 3
 FirstName LastName
Yao (Jessie) Liu
Tuya Inc.
August 15, 2023
Page 3
6.In Footnote 9 of the response to prior comment 5, you state that “As of March 31, 2023
and December 31, 2022, respectively, approximately 1.6% and 1.5% of the Company’s
total assets, consolidated with its wholly-owned subsidiaries, consists of long-term equity
and debt securities held by Zhejiang Smart Electronics.” Please confirm whether these
figures are presented exclusive of U.S. government securities and cash items and, if not,
please provide such figures.
            You may contact Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or
Christine Dietz, Senior Staff Accountant, at (202) 551-3408 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Xiaolang Chai, Capital Market Director