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CORRESP
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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.

January 19, 2024

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 Fiscal Year Ended December 31, 2022

Response dated November 22, 2023

File No. 001-40210

Attn: Office
of Technology

VIA EDGAR

Dear Melissa Kindelan and Christine Dietz:

This letter sets forth the response of Tuya Inc.
(the “Company”) to the comment (the “Comment”) contained in a letter the Company received from
the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on December 15,
2023.

For the Staff’s convenience, we have included
herein the Comment in bold, and the Company’s response  is set forth immediately below the Comment.

 1. We appreciate the offer in your response to prior comment 3 to provide a written analysis from your U.S. counsel explaining to
us, on behalf of the company, counsel’s opinion regarding section 3(b)(1) of the Investment Company Act of 1940 regarding certain
of the company’s subsidiaries. The Staff believes that such analysis would be useful and, accordingly, requests that the company
ask its U.S. counsel to provide such analysis. We may have additional comments following receipt of the 3(b)(1) analysis.

Please see attached written analysis
of counsel regarding Section 3(b)(1) of the Investment Company Act of 1940 regarding Tuya (HK) Limited, [***], [***] and [***].

*    *    *    *

CONFIDENTIAL
TREATMENT REQUESTED BY TUYA INC.

    1

If you have further questions or comments regarding,
or require further information or clarification of,  the response provided in this letter or if the Commission has any questions
with respect to Tuya Inc.’s Annual Report on Form 20-F, please contact the undersigned or Li He (+852-2533-3306) of Davis Polk &
Wardwell LLP.

    Sincerely yours,

    Tuya Inc.

    By:
    /s/ Yao (Jessie) Liu

    Name: Yao (Jessie) Liu
 Title: Chief Financial Officer

    cc:
    Li He

Davis Polk & Wardwell LLP

CONFIDENTIAL
TREATMENT REQUESTED BY TUYA INC.

    2

    Davis Polk & Wardwell llp

    450 Lexington Avenue

    New York, NY 10017

    davispolk.com

Memo

    Date:
    January 19, 2024

    To:
    Division of Corporation Finance

U.S. Securities & Exchange Commission

    From:

    Gregory S. Rowland

    Sarah E. Kim

    Matthew R. Silver

    Davis Polk & Wardwell LLP

    Re:
    Tuya, Inc. Subsidiary Analysis under Section 3(b)(1) of the Investment Company Act of 1940, as amended

At
the request of Tuya, Inc. (the “Company”), we have prepared the following analysis to explain to the staff (the
 “Staff”) of the Securities and Exchange Commission (the “SEC”) our opinion regarding the application
of Section 3(b)(1) of the Investment Company Act (the “1940 Act”) to Tuya (HK) Limited, [***], [***]
and [***] (each a “Subsidiary,” and together, the “Subsidiaries”). As discussed in more detail below,
we are of the opinion that each of the Subsidiaries is excluded from the definition of “investment company” by Section 3(b)(1).1

 I. Background

The
Company is primarily engaged through its subsidiaries (including the Subsidiaries) in internet of things (“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, the “IoT Business”). Tuya (HK) Limited is a wholly-owned
subsidiary of the Company, and [***], [***] and [***] are each wholly-owned subsidiaries of Tuya (HK) Limited. The Subsidiaries
are some of the main operating entities through which the Company conducts the IoT Business and as such, the Subsidiaries are each primarily
engaged in the IoT Business.

As a corporate group, the Company and its subsidiaries,
including the Subsidiaries (together, the “Group”) provide a cloud platform that connects a range of devices via the
IoT. Following its establishment, the Group first developed its IoT cloud development platform in May 2015, and as of September 30,
2023, the Tuya IoT cloud development platform has accumulated over 909,000 registered developers from over 200 countries and regions cumulatively
serving more than 7,600 customers. Additionally, smart devices powered by the Group are available in approximately 120,000 stores worldwide.
Since its establishment, the Group has continued to focus on optimizing its existing platform and incubating various applications in the
IoT cloud development platform field.

1 The analysis discussed herein is based on the facts and
information provided to us by the Company, which we have not independently verified. The Company has reviewed this memorandum and has
informed us that the facts and information recited herein are correct. We have no obligation to update the analysis set forth herein
to reflect any changes in law or circumstance.

    A-1

    Division of Corporation
Finance

U.S. Securities & Exchange Commission

In growing its IoT Business, the Group has dedicated
significant resources to creating new technology, which has resulted in numerous successful technological developments. For example, the
Group uses its funds to enhance its IoT cloud technologies and infrastructure, including its: Thing Technology Platform, which provides
strong basic IoT capabilities such as cloud computing, digital twins and AI-based algorithms, to allow the Group’s products to be
used for more innovated use cases; Business Technology Platform, which lays the necessary technology groundwork to provide customers with
more diversified IoT capabilities in ways that better suit their specific needs and preferences; and Application Enabling Platform, which
offers developer-friendly, low-code and no-code environments so that developers can more quickly and cost-effectively create, customize
or integrate systems and functionality for their specific needs. These innovative technologies have been critical to the Group’s
success, building high commercial barriers and first mover advantages, and will continue to support the Group’s long-term development.
Additionally, by 2023 the Group had registered approximately 478 patents, 1,005 trademarks, 145 copyrights and 127 domain names globally.
As a leading company in the field, the Company is an active participant in many industry alliances and partnerships, such as being a member
of the board of directors of the Connectivity Standards Alliance (the management institution of Matter, a worldwide IoT connectivity protocol),
being a member of the ioXt Alliance (creator of global IoT security standards and one of the fastest growing IoT security certification
bodies) and being a member of the China Household Electrical Appliances Association, to take the lead in formulating IoT device industry
standards.

 II. Definition of Investment Company

Section 3(a)(1)(C) of the 1940 Act defines
an “investment company” as an issuer that “is engaged or proposes to engage in the business of investing, reinvesting,
owning, holding, or trading in securities, and owns or proposes to acquire investment securities having a value exceeding 40 per centum
of the value of such issuer’s total assets (exclusive of Government securities and cash items) on an unconsolidated basis.”2

As
applied to the Subsidiaries, each Subsidiary passes the 40% Test because less than 40% of each Subsidiary’s total unconsolidated
assets (excluding U.S. government securities and cash items, including short-term bank time deposits) consists of investment securities.
Additionally, over 60% of the total unconsolidated assets (excluding U.S. government securities and cash items, including short-term bank
time deposits) of each Subsidiary, other than [***], consists of operating assets such as fixed assets, right-of-use assets and
receivables.3 We believe that short-term bank time deposits
with maturities of one year or less are cash items for purposes of the 40% Test,4
but even if such short-term deposits were considered investment securities,5
each of the Subsidiaries is still not an investment company under Section 3(b)(1) of the 1940 Act, based on the Tonopah Mining
factors discussed in this memorandum.

2
We refer to the 40% asset test as the “40% Test.”

3
As of September 30, 2023, [***]’s only assets consisted of cash items, including short-term time deposits.

4
See Certain Prima Facie Investment Companies, SEC Release No. 10937 (Nov. 13, 1979).

5
For purposes of this analysis only, we have assumed that short-term deposits maturing in one year or less are securities
and not cash items, though we believe that such short-term deposits are cash items.

    A-2

    Division of Corporation
Finance

U.S. Securities & Exchange Commission

Section 3(b)(1) provides that, notwithstanding
Section 3(a)(1)(C), an issuer is not an investment company if such issuer is “primarily engaged, directly or through a wholly-owned
subsidiary or subsidiaries, in a business or businesses other than that of investing, reinvesting, owning, holding, or trading in securities.”
Therefore, the determination of whether a company is an investment company under Section 3(b)(1) focuses on the company’s
 “primary” business engagement.6 Whether such short-term deposits are treated as cash items for 1940 Act purposes
or not does not change the fundamental nature of the Subsidiaries’ primary engagement as operating companies, and would not change
a reasonable investor’s perception of the Subsidiaries as operating companies rather than “competitor[s] with…closed-end
mutual fund[s].”7

Under
Tonopah Mining Co., (26 S.E.C. 426 (1947)), being “primarily engaged” in a business or businesses other than that
of investing, reinvesting, owning, holding or trading in securities was interpreted under the 1940 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, (4) the nature of its present assets and (5) the sources
of its present income (the “Five Factor Test”).8 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.”9 Although the
SEC and its Staff have from time to time indicated that the nature of a company’s assets and the sources of its income are the
two most important factors, in National Presto the court stated that the nature of a company’s assets is not the most important
of these factors; rather, what is most important is whether the company’s “portfolio and activities [will] lead investors
to treat a firm as an investment vehicle or as an operating enterprise.”10
Applying the Five Factor Test to the Subsidiaries, it is clear that each Subsidiary is primarily engaged in the IoT Business,
and not in the business of investing, reinvesting, owning, holding or trading in securities.

6
See SEC v. Nat’l Presto Indus., Inc. 486 F.3d 305 at 26 (7th Cir. 2007) (stating that Section 3(b)(1) of the
1940 Act is about considerations other than assets (or at least in addition to assets) and stating “what principally matters is
the beliefs the company is likely to induce in investors” and whether “its portfolio and activities [would] lead investors
to treat a firm as an investment vehicle or as an operating enterprise.”). See also Newmont Mining Corp., 36 S.E.C. 429
(1955) (finding that, under the facts presented, a company that was registered as an investment company had ceased to be one and was
instead primarily engaged in mining operations through subsidiaries, even though more than 40% of its assets were in “investment
securities”), and Am. Mfg. Co., 41 S.E.C. 415 (1963) (explaining that the “engaged primarily” analysis is a
factual analysis and can include many types of businesses and business lines in same company).

7
See Nat'l Presto.

8
26 S.E.C. 426 (1947).

9
See Nat’l Presto.

10
Id. (rejecting the assertion that the composition of a company’s assets is the “most important”
of these five consideration and observing that this position would turn the Section 3(b)(1) exclusion into “an odd statutory provision
indeed….Subsection (b)(1) has to be about considerations other than assets (or at least in addition to assets).”)

    A-3

    Division of Corporation
Finance

U.S. Securities & Exchange Commission

 III. Analysis: Five Factor Test

Historical Development

As applied to the Subsidiaries, the Tonopah
Mining factors demonstrate that, like the Company, they are primarily engaged in the business of providing IoT products and services,
and not investing, reinvesting or trading in securities.

The Company has been primarily engaged in the IoT
Business since its establishment in 2014 and the Company does not expect to change its primary business in the future. As discussed further
above, following its establishment, the Company first developed its IoT cloud development platform in May 2015, and as of September 30,
2023, the Company’s IoT cloud development platform has accumulated over 909,000 registered developers from over 200 countries and
regions cumulatively serving more than 7,600 customers. Additionally, smart devices powered by the Company are available in approximately
120,000 stores worldwide. Since its establishment, the Company has continued to focus on optimizing its existing platform and incubating
various applications in the IoT cloud development platform field.

Tuya
(HK) Limited was established in 2014 primarily as a holding company for a majority of the Company’s indirect wholly-owned subsidiaries
that operate the Company’s IoT platform business in the PRC and globally outside the United States. As the holding company for the
Company’s main operating subsidiaries (including [***], [***] and [***]), Tuya (HK) Limited’s business activities include
negotiating vendor contracts with suppliers globally and entering into sales contracts in connection with the export of the Company’s
products and services.

    A-4

    Division of Corporation
Finance

U.S. Securities & Exchange Commission

[***]
was established in 2022 primarily to operate the Group’s IoT platform business in Europe, particularly in [***]. Its business activities
include negotiating vendor contracts with suppliers regionally and entering into sales contracts in connection with the sale of the Group’s
products and services in the relevant regions according to the needs of the Group or its partners’ business arrangements.

[***]
and [***] were established in 2020 and 2021, respectively, primarily to operate the Company’s IoT platform business in China, particularly
in [***] and [***], respectively. The business activities of these two subsidiaries include negotiating vendor contracts with suppliers
regionally and entering into sales contracts in connection with the sale of the Group’s products and services in the relevant regions
according to the needs of the Group or its partners’ business arrangements.

Like the Company, each of the Subsidiaries has
been primarily engaged in the business of providing IoT related products and services since its establishment and does not expect to change
its primary business in the future. Thus, the historical development of the Subsidiaries supports the historical development factor because
they have been primarily engaged in the IoT Business since their establishment.

Public Representations of Policy

In terms