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December 20, 2023

Via EDGAR

United States Securities and Exchange Commission,

Division of Corporation Finance,

Office of Mergers & Acquisitions,

100 F Street, N.E.,

Washington, D.C. 20549.

Attention: Christina Chalk

  Laura McKenzie

 Re: Perfect Corp.

Schedule TO-I/A

Filed December 19, 2023

File No. 005-93810

Ladies and Gentlemen:

Perfect Corp. (the “Company”)
has filed today, via EDGAR, this letter and the Amendment No. 2 to the Schedule TO-I (the “Amendment No. 2”) with the Securities
and Exchange Commission (the “Commission”).  The Company previously filed the Tender Offer Statement on Schedule TO-I on November
27, 2023, as amended and supplemented by the Amendment No. 1 to the Schedule TO-I filed by the Company on December 19, 2023 (including
the exhibits filed therewith, the “Schedule TO”) with the Commission.  The Amendment No. 2 has revised the Schedule TO to reflect
the Company’s responses to the comment letter to the Schedule TO, dated December 19, 2023, from the staff of the Commission (the
 “Staff”).

On behalf of the Company, we
have set forth below the Company’s responses to the Staff’s comments.  The responses and information below are based on information
provided to us by the Company.  To facilitate the Staff’s review, we have included in this letter the caption and comment from the
Staff’s comment letter in bold text and have provided the Company’s response immediately following each comment.  Capitalized
terms used but not otherwise defined herein have the meanings assigned to such terms in the Schedule TO.

Sullivan & Cromwell
(Hong Kong) LLP is affiliated with Sullivan & Cromwell LLP, a limited liability partnership established under the laws of the State
of New York

    United States Securities and Exchange Commission

Division of Corporation Finance

Office of Mergers & Acquisitions

    -2-

The Company has responded to
each of the Staff’s comments by incorporating revisions in the Amendment No.2 in light of the comment.  The page references in the
Staff’s comments refer to page numbers in the offer to purchase, dated November 27, 2023, attached as exhibit (a)(1)(A) to the Schedule
TO (the “Offer to Purchase”).

Schedule TO-I/A filed December 19, 2023

Purpose of the Offer; Certain Effects of the
Offer; Other Plans, page 13

 1. Refer to comment one in our prior comment letter.  We note that your response includes additional background and reasons
for the Offer that are not disclosed in the Schedule TO-I.  Please revise the Schedule TO-I to incorporate information relevant to the
purposes of the transaction.

Response:

In response to the Staff’s comments,
the Company has amended and supplemented the disclosures under “Item 1. Summary Term Sheet.”, “Item 4. Terms of the
Transaction.” and “Item 6. Purposes of the Transaction and Plans or Proposals.” of the Schedule TO.  Please see the Company’s
amendment (1) under “Item 1. Summary Term Sheet.”, amendment (1) under “Item 4. Terms of the Transaction.” and
amendment under “Item 6. Purposes of the Transaction and Plans or Proposals.” in Amendment No.2.

General

 2. We note your response to prior comment five summarizing the impact of the Offer on the Company's financial
statements.  Please incorporate this disclosure in the Schedule TO-I.

Response:

In response to the Staff’s comments,
the Company has amended and supplemented the disclosures under “Item 1. Summary Term Sheet.”, “Item 4. Terms of the
Transaction.” and “Item 10. Financial Statements.” of the Schedule TO. Please see the Company’s amendment (2)
under “Item 1. Summary Term Sheet.”, amendment (2) under “Item 4. Terms of the Transaction.” and amendment under
 “Item 10. Financial Statements.” in Amendment No.2.

*     *     *

    United States Securities and Exchange Commission

Division of Corporation Finance

Office of Mergers & Acquisitions

    -3-

If you would like to discuss
any aspect of the Amendment No. 2, please contact Ching-Yang Lin at +852-2826-8606 or by email (linc@sullcrom.com). Please send written
correspondence relating to this submission by email.

 Very truly yours,

  /s/ Ching-Yang Lin

  Ching-Yang Lin

  Partner

  Sullivan & Cromwell (Hong Kong) LLP

cc: (via e-mail)

Alice H. Chang, Chief Executive Officer

Iris Chen, Head of Finance and Accounting