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10/F, Building A, Huace Center

Xihu District, Hangzhou City

Zhejiang, 310012

People’s Republic of China

    July
    14, 2023

    Division of Corporation
    Finance

    U.S. Securities & Exchange Commission

    100 F Street, NE

    Washington, D.C. 20549

    Re:
    Tuya Inc.

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

    Filed April 26, 2023

    File No. 001-40210

    Attn:
    Office of Technology

VIA EDGAR

Dear Tyler Howes,
Christopher Dunham, Melissa Kindelan and Christine Dietz:

This letter sets
forth the responses of Tuya Inc. (the “Company”) to the comments (the “Comments”) the Company received
from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) in a letter
dated June 15, 2023.

For the Staff’s
convenience, we have included herein the Comments in bold, and the Company’s responses are set forth immediately below the Comments.

General Note
to the Staff:

The Company respectfully submits in
this letter its proposed amendments to the disclosures contained in the Company’s annual report on Form 20-F for the fiscal year
ended December 31, 2022 filed with the SEC on April 26, 2023 (the “2022 Annual Report”). The Company undertakes
to include the proposed disclosures substantially as set forth below in its annual report on Form 20-F for the fiscal year ended December
31, 2023 (the “2023 Annual Report”), to the extent applicable, subject to the Staff’s further review and comment
with appropriate revisions and updates to reflect the Company’s circumstances at the time when it files the 2023 Annual Report.

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

Item 16I. Disclosure
Regarding Foreign Jurisdictions that Prevent Inspections, page 163

 1. We note your statement that
you reviewed your register of members and public filings made by your shareholders in connection with your required submission under
paragraph (a). Please supplementally describe any additional materials that were reviewed and tell us whether you relied upon any legal
opinions or third party certifications such as affidavits as the basis for your submission. In your response, provide a similarly detailed
discussion of the materials reviewed and legal opinions or third party certifications relied upon in connection with the required disclosures
under paragraphs (b)(2) and (3).

Submission under
paragraph (a) of Item 16I

In response to
the Staff’s comment, the Company respectfully advises the Staff that it did not rely on any legal opinions or third-party certifications,
such as affidavits, as the basis for its submission under paragraph (a) of Item 16I on Exhibit 15.4 to the 2022 Annual Report (the “Exhibit
15.4”).

As the Company
has disclosed in its submission under paragraph (a) of Item 16I in Exhibit 15.4, based on an examination of the Company’s register
of members and public filings made by the Company’s shareholders, including the reports of ownership on Schedule 13G (and, where
applicable, the amendments thereto) filed with the SEC (the “Public Filings”), the Company believes it had a reasonable
basis to conclude that it is not controlled by a foreign government entity. As provided in Exhibit 15.4, as of April 9, 2023, certain
entities affiliated with New Enterprise Associates, Tenet Group Limited, Tenet Vision Limited, Tencent Mobility Limited and Image Frame
Investment (HK) Limited, and Unileo Limited beneficially owned approximately 20.7%, 11.9%, 6.1%, 10.1% and 5.0%, respectively, of the
Company’s total outstanding shares, representing 9.8%, 5.7%, 28.9%, 4.8% and 22.4% of the voting power of the Company’s total
outstanding shares as of the same date. Additionally, based on publicly available information and the Company’s further inquiries
to certain shareholders, to the best knowledge of the Company,

 (i) the
                                            abovementioned entities affiliated with New Enterprise Associates are not owned or controlled
                                            by a PRC governmental entity, as confirmed by New Enterprise Associates  to the
                                            Company;

 (ii) Tenet
                                            Group Limited is ultimately wholly owned by the trustee of a trust constituted under the
                                            laws of the Cayman Islands, of which the settlor is Mr. Xueji (Jerry) Wang, the Company’s
                                            director and chief executive officer, and the beneficiaries are Mr. Wang and Tuya Group Inc.;
                                            Tuya Group Inc. is a business company with limited liability incorporated under the laws
                                            of the British Virgin Islands, which is wholly owned by Mr. Wang, a natural persons not affiliated
                                            with any foreign government entities;

 (iii) Tenet
                                            Vision Limited is ultimately controlled by Mr. Xueji (Jerry) Wang, a natural person not affiliated
                                            with any foreign government entities;

 (iv) Tencent
                                            Mobility Limited and Image Frame Investment (HK) Limited are wholly owned subsidiaries of
                                            Tencent Holdings Limited, a company incorporated in the Cayman Islands whose shares are listed
                                            and publicly traded on The Stock Exchange of Hong Kong Limited; Tencent Holdings Limited
                                            has confirmed to the Company that, based on the notices of disclosure of interests
                                            filed by its substantial shareholders pursuant to the Hong Kong Securities and Futures Ordinance,
                                            it is not aware that it is owned or controlled by a PRC governmental entity; and

 (v) Unileo
                                            Limited is a limited liability company incorporated under the laws of the British Virgin
                                            Islands, which is wholly owned by Mr. Liaohan (Leo) Chen, the co-chairman of the Company’s
                                            board of directors and the Company’s president; Mr. Chen is a natural person not affiliated
                                            with any foreign government entities.

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In addition, since
each of the Company’s consolidated subsidiaries is directly or indirectly wholly owned by the Company, the Company has relied upon
the materials as described in the foregoing paragraphs, and did not rely upon additional documentation, to reach its conclusion that
none of these subsidiaries is owned or controlled by any foreign government entities. Furthermore, the Company acknowledges that Item
16I(b) requires that the Company provides disclosures for itself and its consolidated foreign operating entities, including the variable
interest entity (the “VIE”). In this regard, the Company respectfully submits that, as disclosed in the 2022 Annual
Report, a series of contractual arrangements were entered into between Tuya Information, on the one hand, and the VIE and its registered
shareholders, on the other hand. Due to such contractual arrangements, the Company is considered the primary beneficiary of the VIE for
accounting purposes and consolidates the VIE’s operating results in the Company’s financial statements under U.S. GAAP to
the extent the conditions for consolidation of the VIE under U.S. GAAP are satisfied. Based on publicly available information and the
Company’s inquiries to certain relevant shareholders of the VIE, to the best knowledge of the Company, the shareholders of the
VIE are individuals not affiliated with any foreign government entities. Therefore, the Company does not consider the VIE to be owned
or controlled by foreign governmental entities, or that the foreign governmental entities have a controlling financial interest in the
VIE.

Based on the above,
the Company believes it is reasonable to rely on register of members, the Public Filings, other publicly available information, and further
inquiries with certain shareholders as to their government ownership or support to form the basis for the Company to draw the conclusion
as disclosed in its submission under paragraph (a) of Item 16I in Exhibit 15.4.

Required disclosures
under paragraph (b) of Item 16I

With respect to
the disclosures required under paragraph (b)(2) and (b)(3) of Item 16I, the Company has relied on the materials as set forth in submission
under paragraph (a) of Item 16I discussed above, including register of members, the Public Filings and inquiries with certain shareholders
as to their government ownership or support, to form the basis for the Company to draw the conclusion in its disclosure in response to
paragraph (b)(2) and (b)(3) of Item 16I.

 2. In order to clarify the scope
of your review, please supplementally describe the steps you have taken to confirm that none of the members of your board or the boards
of your consolidated foreign operating entities are officials of the Chinese Communist Party. For instance, please tell us how the board
members’ current or prior memberships on, or affiliations with, committees of the Chinese Communist Party factored into your determination.
In addition, please tell us whether you have relied upon third party certifications such as affidavits as the basis for your disclosure.

In response to
the Staff’s comment, the Company respectfully advises the Staff that in preparation of its required disclosure under paragraph
(b)(4) of Item 16I of Form 20-F, the Company has reviewed publicly available information and the Company’s internal records
and further conducted inquiries to the members of the board of directors of Tuya Inc. and its consolidated operating entities (each
a “Director”, collectively “Directors”) to determine whether such Director is an official of
the Chinese Communist Party. The Company has factored the Directors’ current or prior memberships on, or affiliations with,
committees of the Chinese Communist Party, to the extent such information is known to the Company, into its determination in
preparation of its required disclosures under paragraph (b)(4) of Item 16I. The Company did not rely upon third-party certifications
such as affidavits as the basis for disclosure. After taking the foregoing steps, nothing has come to the Company’s attention
suggesting that any Director is an official of the Chinese Communist Party or has any memberships or affiliations that could
reasonably result in such Director being considered an official of the Chinese Communist Party.

Accordingly, the
Company re-confirms that to the best of its knowledge, as of the date of the 2022 Annual Report, none of the members of board of directors
of the Company or each of the Company’s consolidated operating entities was an official of the Chinese Communist Party.

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 3. We note that your disclosures
pursuant to Items 16I(b)(2) and (b)(3) are provided for your “material operating entities.” Please note that Item 16I(b)
requires that you provide disclosures for yourself and all of your consolidated foreign operating entities, including variable interest
entities or similar structures.

 • With respect to (b)(2), please
supplementally clarify the jurisdictions in which your consolidated foreign operating entities are organized or incorporated and provide
the percentage of your shares or the shares of your consolidated operating entities owned by governmental entities in each foreign jurisdiction
in which you have consolidated operating entities in your supplemental response.

 • With
                                            respect to (b)(3), please provide the required information for you and all of your consolidated
                                            foreign operating entities in your supplemental response

In response to
the Staff’s comment, the Company respectfully advises the Staff that its consolidated operating entities are organized or
incorporated in multiple jurisdictions, including the United States, mainland China, Hong Kong, France, United Kingdom, Australia,
Colombia, Germany, Japan, India, the United Arab Emirates, the Cayman Islands, the British Virgin Islands, and
Singapore.

With
respect to (b)(2), the Company respectfully confirms that as of the date of the 2022 Annual Report, none of the shares of the Company
or any of the Company’s consolidated operating entities are owned by governmental entities in the jurisdiction in which the Company
or such operating entities are incorporated or otherwise organized.

With
respect to (b)(3), the Company respectfully advises the Staff that as of the date of the 2022 Annual Report, it is not aware that the
governmental entities in mainland China have a controlling financial interest in the Company or any of the Company’s consolidated
operating entities.

 4. With
                                            respect to your disclosure pursuant to Item 16I(b)(5), we note that you have included language
                                            that such disclosure is “to our best knowledge.” Please supplementally confirm
                                            without qualification, if true, that your articles and the articles of your consolidated
                                            foreign operating entities do not contain wording from any charter of the Chinese Communist
                                            Party.

The
Company respectfully submits that as of the date of the 2022 Annual Report, the then effective memorandum and articles of association
of Tuya Inc. and the articles of incorporation (or equivalent organizing document) of each of the Company’s consolidated foreign
operating entities did not contain any charter of the Chinese Communist Party, including the text of any such charter.

Please
kindly note that this statement is being made without “best knowledge” qualification as indicated in the Staff’s comment.

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General

 5. Please provide a detailed
legal analysis regarding whether Tuya, Inc. (“the Company”) and each of its subsidiaries meet the definition of an “investment
company” under Section 3(a)(1)(A) of the Investment Company Act of 1940 (“Investment Company Act”). In your response,
please address, in detail, each of the factors outlined in Tonapah Mining Company of Nevada, 26 SEC 426 (1947) and provide legal
and factual support for your analysis of each such factor.

The Company respectfully
advises the Staff that it is in the process of performing the necessary analysis under the Investment Company Act and undertakes to provide
the requested responses to the SEC within the timeframe separately communicated to the Staff.

 6. Please provide a detailed
legal analysis regarding whether the Company, and each of its subsidiaries, meets the definition of an “investment company”
under Section 3(a)(1)(C) of the Investment Company Act. In your response, please include all relevant calculations under Section 3(a)(1)(C),
identifying each constituent part of the numerator(s) and denominator(s). Please also describe and discuss any other substantive determinations
and/or characterizations of assets that are material to your calculations. In particular, please discuss whether the Company considers
(i) those assets categorized as “short-term investments” and “long-term investments” in the Company’s Consolidated
Balance Sheets as of December 31, 2021 and December 31, 2022 and (ii) its holdings of interests or shares in its subsidiaries to be “investment
securities” as defined under Section 3(a)(2) of the Investment Company Act, and, in each case, the legal basis for such positions.

The Company respectfully
advises the Staff that it is in the process of performing the necessary analysis unde