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GDEV Inc.

55, Griva Digeni

3101, Limassol

Cyprus

November 6, 2024

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Dave Edgar

    Kathleen Collins

    Re:
    GDEV Inc.

    Form 20-F for the Fiscal Year Ended December 31, 2023

    Filed April 29, 2024

    File No. 001-40758

To the addressees set forth above:

On behalf of GDEV Inc. (the
 “Company”), we have set forth below responses to the comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “SEC”) contained in its letter dated October 23, 2024
with respect to the Form 20-F for the Fiscal Year Ended December 31, 2023 filed on April 29, 2024 by the Company (the “Form 20-F”).
For your convenience, the text of the Staff’s comments is set forth below in bold and italics, followed in each case by the Company’s
responses. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the Form 20-F.

Form 20-F for the Fiscal Year Ended December 31,
2023

Notes to the Consolidated Financial Statements

Note 4. Accounting judgments, estimates and
assumptions

Revenue recognition, page F-28

 1. Please describe in further detail how you account for virtual currency. To the extent you account
for the sale of virtual currency before such currency is used to purchase virtual goods, explain why and provide the specific accounting
guidance you relied upon. In this regard, your disclosures state that for purchases of virtual currency, you allocate the amount between
consumable and durable items "proportionately to the majority of distributed items and relying on expertise in resource content analysis
of [y]our games." In your response, provide us with the amount of revenue recognized from virtual currency sold in each period presented.

    - 2 -

Response:

We respectfully advise the Staff that
players can purchase either virtual currency (gems) or virtual goods within the game environment – which we collectively refer to
as “virtual items” – in order to enhance their game-playing experience.

Virtual currency represents a digital
form of purchasing power used exclusively within a game’s environment. Players can acquire this virtual currency through purchasing
it by way of direct monetary transactions or, alternatively, earn it as a feature of gameplay. Importantly, once purchased or earned,
this virtual currency is non-refundable and cannot be exchanged or converted back into real-world money, nor can it be employed for any
other game.

Virtual currency transactions are structured
such that they can be converted into virtual goods, which enhance the player's gaming experience. The conversion process typically happens
soon after a player acquires the currency, with players exchanging it for virtual goods within the game. As a result, the turnover rate
of virtual currency in our games is relatively high. For example, the turnover rate of virtual currency in our core game Hero Wars (the
game that contributed at least 90% to our total revenues in each of the years 2021, 2022 and 2023) was estimated to be in the range from
6 to 13 days, depending on the specific platform on which the game was played, as of the end of 2023.

The virtual goods are classified as
either “durable” or “consumable,” depending on the period during which they are accessible to the player upon
purchase and the benefits enjoyed from their use. Consumable virtual items are available to the player for only a short period of time
upon purchase and are only usable once before being discarded or destroyed and do not provide lasting benefits. In this respect, consumable
virtual items are recognized at a point in time in accordance with IFRS 15.38. Conversely, durable virtual items are accessible to the
player over an extended period of time and result in a permanent increase of the player’s character’s power and abilities.
As such, these are recognized over a period of time in accordance with IFRS 15.35-37.

Unlike virtual goods, virtual currency
does not have the inherent characteristics of either consumable or durable virtual goods; however, virtual currency can be converted in
either consumable or durable virtual goods, as per the player’s choice. Accordingly, the classification can only be determined upon
such conversion,. In this respect, upon conversion, an analysis is performed in order to identify the percentage of virtual currency converted
to consumable items and the percentage of the virtual currency converted to durable items, within each reporting period. Such percentages
are considered to be the best estimate and are applied by management in order to classify the total balance of virtual currency not yet
converted as of period end.

Taking into consideration the applicable
guidance under IFRS 15.22, 15.27 and 15.29, management has identified that the performance obligations in respect of both virtual currency
and the virtual goods are the Company’s explicit promise to offer its customers the right to use the virtual items and an implied
promise to maintain the digital game environment. It has been further assessed that the aforementioned performance obligations are not
distinct, as they are highly interrelated and interdependent; as such, the respective performance obligations are accounted for as a single
performance obligation.

Based on the above, no revenue is recognized
until virtual currency is converted. The converted virtual currency follows the same revenue recognition pattern as for virtual goods,
i.e., consumables are recognized at a point in time, while durables are recognized over time, using the revenue deferral model.

With regard to the virtual currency
not yet converted as of period end, the following is applied by management: first, the total balance of virtual currency that has not
be converted is split between consumable virtual items and durable virtual items, based on the pattern of the virtual currency that has
been converted in the period, as described above.

    - 3 -

The value of virtual currency estimated
to be converted into consumable virtual goods is excluded from the amount of revenue recognized in the period and, in this regard, the
revenue for the period recognized in the Company’s consolidated financial statements does not include any balance from the virtual
currency purchased in the period but not converted as of year-end. Accordingly, such purchased-but-still-unconverted virtual currency
is recognized at a point in time in the subsequent reporting period – during which period the virtual currency is expected to be
converted - following effectively the same revenue recognition pattern as the consumable virtual goods, described above. The respective
balance of unconverted virtual currency as at December 31, 2023 and 2022 is US$ 485,000 and US$ 780,000, respectively. Such balance
became realized and was recognized as revenue in the consolidated statement of comprehensive income in 2024 and 2023, respectively.

As far as the balance of virtual currency
expected to be converted into durable virtual goods is concerned, the amount of that balance is incorporated in the deferral model applied
by management upon purchase of the virtual currency and follows the same recognition pattern as for durable virtual goods. Taking into
consideration the typically short period elapsing between the purchase of the virtual currency and the conversion into a durable virtual
good by the player (i.e., up to 2 weeks), revenue from the respective balance will commence to be realized as part of the deferral
model within the same reporting period as the one in which the conversion for virtual goods will take place.

The table below presents the estimated
amounts related to in-app bookings, in-app bookings resulting from acquisition of virtual currency by players and revenues attributed
to these bookings for each of the years ended December 31, 2021, 2022 and 2023(1) (all amounts in millions of US$
unless indicated otherwise):

    Year ended December 31,

    Parameter
    2021
    2022
    2023

    Total in-app bookings
      534
      410
      375

    thereof:

    bookings resulting from acquisition of virtual currency by players
      334
      222
      171

    bookings not recognized as revenues in the period when they originated (recorded as a part of the deferred revenues in the statement of financial position as at the end of thespecific year)
      202
      129
      98

    Revenue recognized in the specific year attributed to bookings resulting from the acquisition of virtual currency by players in the same year
      132
      93
      73

    Revenue recognized in the specific year attributed to bookings resulting from the acquisition of virtual currency by players in the same year as a percentage of the total amount of bookings resulting from the acquisition of virtual currency by players in the same year
      40 %
      42 %
      43 %

 (1) The amounts presented in the table above relate solely to Hero Wars, which is the main title of the Group,
representing over 90% of total bookings for each reporting period presented in the Form 20-F. The amounts represent estimates, as
preparing actual data is highly complex and would require considerable time and exclude certain adjustments in respect of indirect taxes.

    - 4 -

 2. We note three of your operating segments, Cubic Games Studio Ltd, MX Capital Ltd and Castcrown Ltd,
are not considered to be reportable segments based on the quantitative threshold criteria in IFRS 8. Please provide us with the quantified
analysis for each segment that supports your conclusion. Refer to IFRS 8.13. In addition, considering you account for MX Capital and Castcrown
as equity method investments, tell us how you have reflect their operations in your segment disclosures. In your response, address the
fact that these equity method investments are included as an adjustment to segment management EBITDA.

Response:

We respectfully advise the Staff that
GDEV Inc. is a group of companies (the “Group”) comprising numerous legal entities. The following table sets forth
all of the significant entities of the Group and whether they are attributable to an operating segment of the Group or not:

    Company
    Activities
    Segment/

Business Activity

    GDEV Inc.
    Holding Company
    Not a segment – corporate activity

    Nexters Global Ltd
    Nexters Global Ltd was incorporated in Larnaca, Republic of Cyprus on November 2, 2009. The company’s principal activities are game development and publishing.
    Nexters Global Ltd

    Flow Research S.L.
    Flow Research S.L. was incorporated in Barcelona, Spain, on November 10, 2017. The company’s principal activities are creative design of online games.
    Nexters Global Ltd

    NHW Limited
    NHW Ltd was incorporated in Larnaca, Republic of Cyprus on March 9, 2020.  The company’s principal activities are publication and testing of program applications.
    Nexters Global Ltd

    Nexters Studio Armenia LLC
    Nexters Studio Armenia LLC was incorporated in Yerevan, Armenia on April 8, 2022. The company’s principal activities are game development and support.
    The entity is a Group development center. It serves the operating segments Nexters Global and Cubic Games among others. The costs of Nexters Studio Armenia are allocated to the operating segments based on the actual costs incurred by Nexters Studio Armenia on behalf of the specific operating segments.

    - 5 -

    Dragon Machines Ltd

(ex SGBOOST Limited, ex Synergame)
    Synergame Investment Ltd was incorporated in Limassol, Republic of Cyprus on September 1, 2021. The company’s principal activity are M&A activities, game development as well as the provision of independent developers with expertise and funds needed to launch their games and build successful international businesses. The company was renamed on May 12, 2022 to SGBOOST Limited and, subsequently, to Dragon Machines Ltd on July 18, 2023.
    Not a segment – corporate activity

    Nexters Finance Ltd
    Nexters Finance Ltd was incorporated in Limassol, Republic of Cyprus on April 7, 2023. The company's principal activities are financial activities such as provision of intra-group loans.
    Not a segment – corporate activity

    Cubic Games Studio Ltd

(ex Lightmap Ltd)
    This group of companies encompasses five legal entities, four of which – Lightmap Ltd, Cubic Games Ltd, Kadexo Ltd, Fellaway Ltd – are incorporated in Cyprus, while the fifth – Lightmap LLC – was incorporated in Russia and has been liquidated. Lightmap Ltd is the owner of intellectual property (IP) rights. Cubic Games Ltd and Kadexo Ltd are the publishers of the games Pixel Gun 3D (“PG3D”) and Block City Wars (“BCW”), respectively. Fellaway Ltd is dormant and is in the process of liquidation. Lightmap Ltd had an investment in another subsidiary entity, Britglow Ltd, which was also liquidated. The group was renamed on July 18, 2023 to Cubic Games Studio Ltd.
    Cubic Games Ltd

    - 6 -

    Nexters Studio Kazakhstan Ltd
    Nexters Studio Kazakhstan Ltd was incorporated in Astana, Republic of Kazakhstan on May 5, 2022. The company’s principal activities are game development and support.
    The entity is a Group development center. It serves the operating segment Nexters Global, and therefore all its costs are allocated to Nexters Global.

    GDEV Investments Ltd

(ex Tourish Limited)
    Tourish Limited was acquired in Nicosia, Cyprus on May 29, 2023. The company has not yet started its active operations. The company was renamed Nexters Investments Ltd on October 26, 2023.
    No activities

    Nexters Lithuania UAB
    Nexters Lithuania UAB was incorporated in Vilnus, Lithuania on June 27, 2023. The company has not yet started its active operations.
    No activities

    Nexters Midasian FZ LLC
    Nexters Midasian FZ LLC was incorporated in Ras Al Khaimah Economic Zone in UAE on January 24, 2023. The company has not yet started its active operations.
    No activities

    Nexters Studio Portugal, Unipessoal LDA
    Nexters Studio Portugal, Unipessoal LDA was incorporated in Lisboa, Portugal on February 2, 2023. The company has not yet started its active operations.
    No activities

Pursuant to IFRS 8.13, an entity shall
report separately information about an operating segment that meets any of the following quantitative thresholds2:

 a) its reported revenue, including both sales to external customers and intersegment sales or transfers,
is 10 per cent or more of the combined revenue, internal and external, of all operating segments, i.e., Test 1.

 2 We respectfully advise the Staff that while preparing these analysis we have uncovered certain
                                                                             errors in the presentation of the reportable segment data in 2022 both in the presentation of segment revenue and segment management
                                                                             EBITDA, which, nevertheless, does not change our conclusion that we only had one reportable segment in 2022. We do not consider
                                                                             these errors to be material and respectfully advise the Staff that we will correct them when filing our annual report on Form 20-F
                                                                             for the year ended December 31, 2024.

    - 7 -

Test 1

2021

    Operating Segment
    Revenue
    Threshold

results
    Meet test to be

considered

reportable

segment?

    Nexters Global Ltd
    434,094
    100%
    Yes

    GDEV Inc
    –
    –
    Not an operating segment

    SG Boost Ltd.
    –
    –
    Not an operating segment

    Combined Revenue of all operating segments
    434,094
    100%

2