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10/F, Building A, Huace Center

Xihu District, Hangzhou City

Zhejiang, 310012

People’s Republic of China

    CERTAIN PORTIONS OF THIS LETTER AS FILED VIA EDGAR HAVE BEEN OMITTED AND FILED SEPARATELY WITH THE SECURITIES AND EXCHANGE COMMISSION. CONFIDENTIAL TREATMENT HAS BEEN REQUESTED FOR THE OMITTED PORTIONS, WHICH HAVE BEEN REPLACED WITH “[***]” IN THE LETTER FILED VIA EDGAR.

    September 29, 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 Melissa Kindelan and Christine Dietz:

This letter sets forth the responses of Tuya Inc.
(the “Company”) to the comments (the “Comments”) contained in a letter the Company received from
the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on August 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.

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.”

The Company respectfully notes, as has been previously discussed with
the Staff, that the subsidiaries of the Company that were not included in the prior responses were not, and still are not, material to
the Investment Company Act analysis of the Company. Nonetheless, in order to respond to the Staff’s comment and as discussed with
the Staff, we have provided below additional information regarding such other subsidiaries that demonstrates that they do not raise Investment
Company Act issues for the parent or for themselves.

    CONFIDENTIAL TREATMENT REQUESTED BY TUYA INC.

1

With respect to the subsidiaries of the Company other than the Significant
Subsidiaries (as defined below) (the “Immaterial Subsidiaries”), the analysis provided in response to Comment 2 below with
respect to Section 3(a)(1)(A) also applies to the Immaterial Subsidiaries and shows that they are not investment companies thereunder
(with the exceptions discussed in the following paragraph).

The Immaterial Subsidiaries are also not investment companies under
Section 3(a)(1)(C), as each Immaterial Subsidiary holds an immaterial amount of investment securities (if any) compared to its total
assets (excluding cash items and U.S. government securities), with two exceptions.1 The exceptions are that the assets of
two Immaterial Subsidiaries consist primarily of investment securities. The Company treats the interests in such subsidiaries as investment
securities, but that does not affect the Company’s non-investment company act status under Section 3(a)(1)(C), because the
value of such interests are immaterial to the Company. In particular, as of June 30, 2023, the Company’s interest in such subsidiaries
amounts to approximately USD11.7 million or 0.8% of the Company’s total unconsolidated assets (exclusive of U.S. government securities
and cash items).2 Further, as of June 30, 2023, such subsidiaries’ holdings of investment securities amounts to
approximately USD2.3 million or 0.2% of the Company’s total unconsolidated assets (exclusive of U.S. government securities and cash
items).3 As such, treating the interests in such Immaterial Subsidiaries as investment securities does not cause the Company
to be an investment company under Section 3(a)(1)(C). With respect to such Immaterial Subsidiaries’ own Investment Company
Act status, they are wholly-owned non-U.S. subsidiaries of the Company that operate outside of the United States and have not offered
securities in the United States. As such, to the extent such subsidiaries require an Investment Company Act exemption (which they may
not given their offshore nature), they could rely on Section 3(c)(1) or Section 3(c)(7) (as well as, potentially,
Section 3(b)(3) or Rule 3a-3).

Additionally, in order to respond to the Staff’s comment below
with respect to calculations assuming short-term deposits are not treated as cash items, please see footnotes below which set out the
effect of assuming short-term deposits are not cash items.

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.

In addition to the updated response below (with respect to prior Comment
5), please see the response to Comment 3 below (with respect to prior Comment 6).4

1
       Nonetheless, for purposes of the Company’s Investment Company Act analysis
described in these responses, the Company has, for the sake of efficiency, treated the interests in the Immaterial Subsidiaries as investment
securities, which does not affect the analysis given their immaterial value.

2
       We note that treating short-term deposits as not being cash items – per
Comment 4 – would not change these figures as the Company does not hold any short-term deposits itself.

3
       We note that treating short-term deposits as not being cash items – per
Comment 4 – would not change these figures as the Company does not hold any short-term deposits itself.

4
       We note that we have added footnotes through the following discussion to show
 – per Comment 4 – the effect on the calculations of not treating short-term deposits as cash items.

    CONFIDENTIAL TREATMENT REQUESTED BY TUYA INC.

2

The Company respectfully submits the updated 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.”5 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:

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 June 30, 2023, the Tuya IoT cloud development platform has accumulated over 846,000 registered developers from over 200
countries and regions cumulatively 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 Comment 6 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 Comment 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).6

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

6       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 June 30, 2023, on an amortised cost basis,
Tuya (HK)’s interest in Zhejiang Smart Electronics amounts to approximately USD39.6 million or 7.6% of Tuya (HK)’s total
unconsolidated assets (exclusive of U.S. government securities and cash items) which amounts to approximately USD518.0 million. The Company
notes that on Tuya (HK)’s unconsolidated balance sheet as of June 30, 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). If the Company’s short-term deposits were not treated as cash items,
as of June 30, 2023, on an amortised cost basis, Tuya (HK)’s interest in Zhejiang Smart Electronics amounts to approximately USD39.6
million or 3.0% of Tuya (HK)’s total unconsolidated assets (exclusive of U.S. government securities and cash items, assuming short-term
deposits are not cash items) which amounts to approximately USD1,321.4 million. The Company notes that on Tuya (HK)’s unconsolidated
balance sheet as of June 30, 2023, assuming short-term deposits are not cash items, 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).

    CONFIDENTIAL TREATMENT REQUESTED BY TUYA INC.

3

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.

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.

    CONFIDENTIAL TREATMENT REQUESTED BY TUYA INC.

4

In addition, as of June 30, 2023, Tuya had approximately 1,694
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.

4)            In
terms of the assets factor, as discussed in detail below in response to Comment 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.

5)            In
terms of the sources of the Company’s present income, the Company’s net loss of approximately USD99.3 million for the four
fiscal quarters ended June 30, 2023 combined, consolidated with its wholly-owned subsidiaries, was mainly driven by large operating
revenues of approximately USD194.8 million, large cost of revenue of USD107.3 million and operating expenses of approximately USD223.8
million. For that period, interest income amounting to approximately USD41.5 million was attributable to cash items such as bank demand
deposits and short-term bank time deposits maturing in one year or less7
(which, as discussed in our response to Comment 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 USD0.9 million related
to the Company’s short-term and long-term equity and debt securities, representing 0.9% of the Company’s net loss for that
time period. 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 the Company is not primarily engaged in the business of investing, reinvesting or trading in securities. The Company
is thus primarily engaged in the IoT Business, and is not an investment company under Section 3(a)(1)(A).

7       We
note