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10/F, Building A,
Huace Center

Xihu District, Hangzhou
City

Zhejiang, 310012

People’s Republic of China

    August
    4, 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 5 and 6 (the “Comments”) contained
in a letter the Company received from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”)
on 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.

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 submits the
analysis below with respect to the factors outlined in Tonopah Mining Co. (26 S.E.C. 426 (1947)), which demonstrates that the
Company and its subsidiaries (collectively, “Tuya”) are primarily engaged in internet-of-thing (“IoT”)
related product and service offerings, including Platform-as-a-Service and Software-as-a-Service, based on a purpose-built cloud development
platform, as well as cloud-based value-added services (collectively, “IoT Business”), and are not and do not hold
themselves out as being engaged primarily, and do not propose to engage primarily, in the business of investing, reinvesting or trading
in securities. Under Tonopah Mining, being “primarily engaged” in a business or businesses other than that of investing,
reinvesting, owning, holding or trading in securities was interpreted under the Investment Company Act to depend on a facts and circumstances
review, including the following principal factors: (1) an issuer’s historical development, (2) its public representations of policy,
(3) the activities of its officers and directors and, most importantly, (4) the nature of its present assets and (5) the sources of its
present income. Any one factor is not determinative, and as interpreted by the courts, the overarching objective of the Tonopah Mining
analysis is to determine whether reasonable investors would view an issuer “as an operating company rather than a competitor
with a closed-end mutual fund.”1 Applying such factors to Tuya, it is clear that Tuya is primarily engaged in the IoT
Business, and not in the business of investing, reinvesting or trading in securities:

    1

A. The Company

1)       Tuya
is primarily engaged in the business of providing IoT related products and services. Tuya provides a cloud platform that connects a range
of devices via the IoT. The development of Tuya’s business supports the historical development factor, as it has been primarily
engaged in the business of providing IoT related products and services since its establishment in 2014 and Tuya does not expect to change
its primary business in the future. Following its establishment, Tuya first developed its IoT cloud development platform in May 2015,
and as of March 31, 2023, the Tuya IoT cloud development platform has accumulated over 782,000 registered developers from over 200 countries
and regions serving more than 7,600 customers. Additionally, smart devices powered by Tuya are available in approximately 120,000 stores
worldwide. Since its establishment, Tuya has continued to focus on optimizing its existing platform and incubating various applications
in the IoT cloud development platform field.

Tuya has historically maintained significant
cash amounts required for its working capital needs, which Tuya has generally held as cash in bank demand deposits and short-term bank
time deposits maturing in one year or less. Tuya also holds small amounts of long-term and short-term equity and debt securities which,
as further discussed in our response to Question 6 of the Staff’s comments below, Tuya has treated as “investment securities”
for purposes of the analysis under Section 3(a)(1)(C) set out below. In addition, as further discussed in our response to Question 6
below, the amount of Tuya’s long-term and short-term equity and debt securities is not significant enough to cause the Company
to be deemed an investment company under Section 3(a)(1)(C).2

Thus, Tuya’s historical development
has not focused on investing, reinvesting or trading in securities, but instead has been marked by a significant growth in Tuya’s
IoT Business.

_________________

1 SEC
v. Nat'l Presto Indus., 486 F.3d 305 at 26 (7th Cir. 2007) (citing Tonopah Mining (26 S.E.C. 426 (1947)).

2 The
Company owns a portion of such securities through its indirect wholly-owned subsidiary, Zhejiang Tuya Smart Electronics Co., Ltd. (“Zhejiang
Smart Electronics”). Zhejiang Smart Electronics is a wholly-owned subsidiary of Tuya (HK), which is a wholly-owned subsidiary
of the Company and, as further discussed below, is not an investment company under Section 3(a)(1)(C). As a majority of Zhejiang Smart
Electronics’ assets are long-term and short-term equity and debt securities, the Company has treated Tuya (HK)’s interest
in Zhejiang Smart Electronics as an investment security for purposes of this analysis. As of March 31, 2023, on an amortised cost basis,
Tuya (HK)’s interest in Zhejiang Smart Electronics amounts to approximately USD39.6 million or 7.7% of Tuya (HK)’s total
unconsolidated assets (exclusive of U.S. government securities and cash items) which amounts to approximately USD514.7 million. The Company
notes that on Tuya (HK)’s unconsolidated balance sheet as of March 31, 2023, its interest in Zhejiang Smart Electronics would have
zero value due to share of losses, and therefore on a balance sheet basis, amounts to 0% of Tuya (HK)’s total unconsolidated assets
(exclusive of U.S. government securities and cash items).

    2

2)       In
terms of the public representation factor, since Tuya’s establishment in 2014, Tuya has consistently described itself as the provider
of IoT cloud software solutions. For example, Tuya’s press releases typically refer to Tuya as “a
global leading IoT cloud development platform with a mission to build an IoT developer ecosystem and enable everything to be smart.”
Tuya has never represented that it is involved in any business other than the development and operation of IoT cloud software solutions.
Tuya has consistently stated in its filings with the Commission, press releases, other public statements, website and advertising and
marketing materials that it is in the business of providing IoT related products and services as described above.

Furthermore, Tuya has consistently emphasized
its operating results, and has never emphasized either its investment income, or the possibility of significant appreciation from its
cash management activities, as a material factor in its business or future growth. In addition, investors and the investment media outlets
do not evaluate Tuya based on its cash management or investment activities. Instead, research reports and analysis of Tuya focus on its
financial results from its ongoing operations and the development of its business in the IoT cloud development platform field.

3)       The
allocation of Tuya’s officers’ and directors’ time supports the activities factor. All of Tuya’s most senior
executive officers and directors generally spend approximately 99.9% of their time on general corporate matters and the development and
management of Tuya’s IoT cloud software solutions business, and 0.1% or less of their time on matters related to Tuya’s investment
securities.

In addition, as of March 31, 2023, Tuya
had approximately 1,780 employees, of which only 2 employees are responsible for managing Tuya’s investment securities. As such,
approximately 99.9% of Tuya’s employees are dedicated to Tuya’s operating business and general support services for the corporate
group, and approximately 0.1% of Tuya’s employees are responsible for managing Tuya’s investment securities. 3

4)       In
terms of the assets factor, as discussed in detail below in response to Question 6 of the Staff’s comments, the Company is not
an investment company under the assets test under Section 3(a)(1)(C). Thus, the composition of the Company’s assets also demonstrates
that it is not primarily engaged in the business of investing, reinvesting or trading in securities.

_________________

3 The
analysis of the Company under the Investment Company Act is also substantially similar as of December 31, 2022, as illustrated by the
information as of December 31, 2022 the Company has provided in this and subsequent footnotes. As of December 31, 2022, Tuya had approximately
1,835 employees, of which only 2 employees are responsible for managing Tuya’s investment securities. As such, approximately 99.9%
of Tuya’s employees are dedicated to Tuya’s operating business and general support services for the corporate group, and
approximately 0.1% of Tuya’s employees are responsible for managing Tuya’s investment securities.

    3

5)       In
terms of the sources of the Company’s present income, the Company’s net loss of approximately USD111.6 million for the four
fiscal quarters ended March 31, 2023 combined, consolidated with its wholly-owned subsidiaries, was mainly driven by large operating
revenues of approximately USD200.3 million, large cost of revenue of USD112.7 million and operating expenses of approximately USD232.0
million. For that period, interest income4 amounting to approximately USD32.6 million was attributable to cash items such
as bank demand deposits and short-term bank time deposits maturing in one year or less (which, as discussed in our response to Question
6 below, the Company treats as cash items for purposes of the 40% Test (as defined below)). The only potential investment income or loss
of the Company for that time period was investment loss in the amount of USD0.2 million related to the Company’s short-term and
long-term equity and debt securities, representing 0.2% of the Company’s net loss for that time period.5 Such amounts
are clearly outweighed by the large amounts of operating revenues for that period and thus, the primary contributors to the Company’s
net loss also demonstrate that it is not primarily engaged in the business of investing, reinvesting or trading in securities.

As Tonopah Mining makes clear,
whether an issuer is primarily engaged in investing in securities depends on all of the facts and circumstances. The analysis under each
Tonopah Mining factor demonstrates that Tuya is not primarily engaged in the business of investing, reinvesting or trading in
securities. Tuya is thus primarily engaged in the IoT Business, and is not an investment company under Section 3(a)(1)(A).

B. Subsidiaries

1)       The
historical development of the significant subsidiaries (and certain other subsidiaries) of the Company6 (“Significant
Subsidiaries”) demonstrates that such subsidiaries, like Tuya, are primarily engaged in the business of providing IoT products
and services, and not investing, reinvesting or trading in securities.

 · Tuya
                                            Market Inc. (“Tuya Market”) and Tuya Global Inc. (“Tuya Global”)
                                            were established in 2020 and 2015, respectively, as operating businesses in the United States.
                                            Since its establishment, Tuya Global has been primarily engaged in IoT business development
                                            activities, and does not expect to change its primary business in the future. Tuya Market
                                            has not yet conducted any business activity since its establishment, and when it commences
                                            operations, it will be primarily engaged in IoT business development activities, and does
                                            not expect to change its primary business in the future.

_____________________

4 We
note that a portion of this interest income is classified by the Company as “investment income” for accounting purposes,
as such income relates to the Company’s short-term bank time deposits that mature in greater than three months but less than one
year.

5 The
Company’s net loss of approximately USD145.5 million for the four fiscal quarters ended December 31, 2022 combined, consolidated
with its wholly-owned subsidiaries, was mainly driven by large operating revenues of approximately USD208.2 million, large cost of revenue
of USD118.7 million and operating expenses of approximately USD 257.0 million. For that period, interest income amounting to approximately
USD22.8 million was attributable to cash items such as bank demand deposits and short-term bank time deposits maturing in one year or
less (which, as discussed in our response to Question 6 below, the Company treats as cash items for purposes of the 40% Test). The only
potential investment income or loss of the Company for that time period was investment loss in the amount of USD2.2 million related to
the Company’s short-term and long-term equity and debt securities.

6 A corporate
structure chart setting out the Company’s significant subsidiaries, as well as Hangzhou Tuya Technology Co., Ltd. (the “VIE”)
and certain other subsidiaries, is included in Item 3 of the Company’s Form 20-F.

    4

 · Tuya
                                            (HK) Limited (“Tuya (HK)”) was established in 2014 primarily as a holding
                                            company for Tuya’s indirect wholly-owned subsidiaries listed below and, like Tuya,
                                            has been primarily engaged in the business of providing IoT related products and services,
                                            and does not expect to change its primary business in the future. Since their establishment,
                                            each of the following subsidiaries has been primarily engaged in IoT business development
                                            activities or the provision of IoT related products and services, and does not expect to
                                            change its primary business in the future.

 o Tuya France

 o Tuya UK Limited

 o Tuya Smart Australia Pty Ltd.

 o Tuyasmart (Colombia) S.A.S.

 o Tuya GmbH

 o Tuya Japan Co., Ltd.

 o Tuyasmart (India) Private Limited

 o Xiamen Tuya Technology Co., Ltd.

 o Guangdong Tuya Smart Information Technology
                                            Co., Ltd.

 o Shanghai Tuya Information Technology
                                            Co., Ltd.

 o Ningbo Tuya Smart Electronics Co., Ltd.

 o Hangzhou Tuya Information Technology
                                            Co., Ltd.

 o Zhejiang Tuya Smart Electronics Co.,
                                            Ltd.

 o Hefei Tuya Smart Technology Co., Ltd.7

The historical development of the Company’s
Significant Subsidiaries supports the historical development factor because such subsidiaries have been primarily engaged in the IoT
Business since their establishment, and have not been engaged in investing, reinvesting or trading in securities.

2)       In
terms of the public representation factor, the Company generally does not separately describe its subsidiaries