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January 18, 2024
Anthony Page
Chief Financial Officer
Captivision Inc.
298-42 Chung-buk Chungang-ro Chung-buk
Pyeong-taek, Gyounggi, Republic of Korea
Re:Captivision Inc.
Registration Statement on Form F-1
Filed December 22, 2023
File No. 333-276243
Dear Anthony Page:
            We have conducted a limited review of your registration statement and have the
following comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Form F-1 filed December 22, 2023
Cover Page
1.For each of the securities being registered for resale, disclose the price that the selling
securityholders paid for such securities.
Risk Factors, page 16
2.Include an additional risk factor highlighting the negative pressure potential sales of
shares pursuant to this registration statement could have on the public trading price of the
ordinary shares. To illustrate this risk, disclose the purchase price of the securities being
registered for resale and the percentage that these shares currently represent of the total
number of shares outstanding. Also disclose that even though the current trading price is
significantly below the SPAC IPO price, the private investors have an incentive to sell
because they will still profit on sales because of the lower price that they purchased their
shares than the public investors.

 FirstName LastNameAnthony Page
 Comapany NameCaptivision Inc.
 January 18, 2024 Page 2
 FirstName LastNameAnthony Page
Captivision Inc.
January 18, 2024
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
102
3.We note your disclosure on the cover page that the likelihood that holders determine to
exercise their warrants, and therefore the amount of cash proceeds that you would receive,
is dependent upon the market price of your ordinary shares. Provide similar disclosure in
MD&A and disclose that cash proceeds associated with the exercises of the warrants are
dependent on the stock price. As applicable, describe the impact on your liquidity and
update the discussion on the ability of your company to fund your operations on a
prospective basis with your current cash on hand.

4.In light of the significant number of redemptions and the unlikelihood that the company
will receive significant proceeds from exercises of the warrants because of the disparity
between the exercise price of the warrants and the current trading price of the ordinary
shares, expand your discussion of capital resources to address any changes in the
company’s liquidity position since the business combination. If the company is likely to
have to seek additional capital, discuss the effect of this offering on the company’s ability
to raise additional capital.
5.Please expand your discussion here to reflect the fact that this offering involves the
potential sale of a substantial portion of shares for resale and discuss how such sales could
impact the market price of the company’s common stock. Your discussion should
highlight the fact that Jaguar Global Growth Partners I, LLC, a beneficial owner of 47.6%
of your outstanding shares, will be able to sell all of its shares for so long as the
registration statement of which this prospectus forms a part is available for use.
Executive Compensation, page 155
6.Please update your compensation disclosure to reflect the fiscal year ended December 31,
2023 and provide the information required by Item 6.B of Form 20-F.
General
7.Revise your prospectus to disclose the price that each selling securityholder paid for the
securities being registered for resale. Highlight any differences in the current trading
price, the prices that each selling securityholder acquired their shares and warrants, and
the price that the public securityholders acquired their shares and warrants. Please also
disclose the potential profit the selling securityholders will earn based on the current
trading price. Lastly, please include appropriate risk factor disclosure.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate

 FirstName LastNameAnthony Page
 Comapany NameCaptivision Inc.
 January 18, 2024 Page 3
 FirstName LastName
Anthony Page
Captivision Inc.
January 18, 2024
Page 3
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Bradley Ecker at 202-551-4985 or Evan Ewing at 202-551-5920 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing