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August 1, 2023
James Knopf
Chief Executive Officer
Gamer Pakistan Inc
35 E Horizon Ridge Parkway, Suite 110-481
Henderson, NV 89002-7906
Re:Gamer Pakistan Inc
Registration Statement on Form S-1
Filed July 12, 2023
File No. 333-273220
Dear James Knopf:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-1 Filed July 12, 2023
Prospectus Summary, page 1
1.We note your response to comment 2 and reissue in part. You have amended your
disclosure on page 3 of the registration statement clarifying the nature of the agreement
between IUCPSS and ESP. Please make corresponding changes to the disclosure on page
44 where the agreement between IUCPSS and ESP is described. Similarly, we note that
you have added disclosure to page 2 of the registration statement clarifying what is meant
by "organized and conducted," but you have not made similar changes to the disclosure
found on page 29 in the Business section. Please clarify this discrepancy. Lastly, it
remains unclear how the "Logo Agreements" listed relate to your business.

 FirstName LastNameJames  Knopf
 Comapany NameGamer Pakistan Inc
 August 1, 2023 Page 2
 FirstName LastName
James  Knopf
Gamer Pakistan Inc
August 1, 2023
Page 2
2.We note your response to comment 5 and reissue in part. We acknowledge your disclosure
clarifying that to date neither K2 Gamer nor ESP have generated any revenue. Please
indicate the reason why you acquired K2 Gamer given that it has no revenue generating
operations.
Use of Proceeds, page 23
3.With respect to the loan repayment to SII, please disclose the interest rate and maturity.
Refer to Item 504 of Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital, page 27
4.We note the various agreements you have entered into beginning on page 44.  Please
revise to describe your material cash requirements from known contractual obligations.
Refer to Item 303 of Regulation S-K.
Cash Resources and Going Concern, page 28
5.You disclose on December 31, 2022, you had $232,575 in working capital. It appears that
you had $70,544 in working capital. Please revise as necessary.
6.We note your response to comment 18 and reissue in part. We acknowledge the addition
of disclosure to the Business and Related Party sections, but please also update the
disclosure on page 28 to make clear that the $75,000 loan is from Richard Whelan as well
as disclose the $10,750 loan made in 2022.
List of Our 2021-2022 K2 Gamer Esports Events, page 37
7.Please clarify in this section that neither you, K2 Gamer or ESP generated revenue from
any of the events listed here.  With respect to the list of Planned K2 Gamer Esports Events
in 2023, please update the disclosure to reflect that certain of these events have already
occurred.  Please also disclose whether you have or will generate any revenue from the
2023 events.  If you did not generate revenue, please explain your specific role in such
events.
Government Regulations, page 43
8.We note your response to comment 10 and reissue in part. Please disclose the specific
existing laws and regulations that are material to an understanding of your business. We
note that your added disclosure states "Other than the foregoing, there are no existing or
probable laws and regulations that are material to the business of K2 Gamer and ESP."
However, the foregoing disclosure only refers to "various Pakistan and international" tax
laws, rules and regulations in place across each Pakistan jurisdiction. Please disclose these
regulations to assist investors with understanding the regulatory regime in Pakistan.

 FirstName LastNameJames  Knopf
 Comapany NameGamer Pakistan Inc
 August 1, 2023 Page 3
 FirstName LastName
James  Knopf
Gamer Pakistan Inc
August 1, 2023
Page 3
Agreement with Pixel Colony, page 44
9.We note your response to comment 12 and reissue in part. While we acknowledge the
addition of disclosure describing "GAMER Core Platform," please also add disclosure
that describes the material terms of the agreement, such as the obligation to make
payments under the agreement.  For example, please indicate if there is a minimum
payment amount that is guaranteed. In this regard, we note that you are using $1.2 million
of proceeds from the offering for payments under this agreement.
Management, page 45
10.We note your response to comment 13 and reissue. If the board does not consider
board oversight of the company’s cybersecurity risk management to be necessary, please
disclose as much. Alternatively, if there are relevant officers or managers who
oversee cybersecurity risk management and report to the board, please disclose as much.
Certain Relationships and Related-Party Transactions, page 52
11.We note your response to comment 15 and reissue in part. We acknowledge the addition
of cross-references to the Business section to provide details for the related party
transactions. When describing the consulting agreement with Face Rebel, please clarify at
what point the monthly payments of $16,000 will begin, if they haven't already. Refer to
Item 404(a)(6) of Regulation S-K. In addition, when describing the loan agreement with
SII, please also disclose the amount of interest that has been paid so far, or if none, please
disclose as much. Refer to Item 404(a)(5) of Regulation S-K.
Exhibits
12.Please file the consent of your independent registered public accounting firm in your next
amendment.
13.We note that Exhibit 10.4 does not have an asterisk to mark it for future filing, but it has
also not been filed with this registration statement or been previously filed. Please clarify
this discrepancy.
General
14.On page one, you state that to date all activities have been conducted by K2 Gamer and
ESP, and not the Company.  Please tell us how K2 Gamer and ESP conducted these
activities when your June 5, 2023 response to comment 31 indicated that they had
minimal financial statement activity with a zero net loss and $12,088 in total assets.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

 FirstName LastNameJames  Knopf
 Comapany NameGamer Pakistan Inc
 August 1, 2023 Page 4
 FirstName LastName
James  Knopf
Gamer Pakistan Inc
August 1, 2023
Page 4
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Patrick Kuhn at 202-551-3308 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Nalbantian at 202-551-7470 or Erin Jaskot at 202-551-3442 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Edward Swanson