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May 21, 2024
Junkoo Kim
Chief Executive Officer
WEBTOON Entertainment Inc.
5700 Wilshire Blvd., Suite 220
Los Angeles, CA 90036
Re:WEBTOON Entertainment Inc.
Amendment No. 3 to Draft Registration Statement on Form S-1
Submitted May 10, 2024
CIK No. 0001997859
Dear Junkoo Kim:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. 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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
April 26, 2024 letter.
Amendment No. 3 to Draft Registration Statement on Form S-1
Summary Consolidated Financial and Other Data, page 23
1.We note your Income before income tax for the three months ended March 31, 2024 is
presented as a loss. Please revise the table to correct this inconsistency.
Management's Discussion and Analysis of Results of Operations and Financial Condition
Overview, page 82
2.Please clarify or correct the inconsistent dates in the last sentence of the first paragraph
under Overview.

 FirstName LastNameJunkoo Kim
 Comapany NameWEBTOON Entertainment Inc.
 May 21, 2024 Page 2
 FirstName LastName
Junkoo Kim
WEBTOON Entertainment Inc.
May 21, 2024
Page 2
How We Generate Revenue
Paid Content, page 84
3.We note disclosures under Paid Content that “content is purchased by users with Coins
which can be exchanged for access to content that is behind a paywall or received by them
for free during in-app promotional events” and that “users may receive up to a certain
number of Daily Passes for free each day”. Please clarify or confirm that Coins and Daily
Passes received for free are not included in Paid Content or explain to us if and how they
are included.

Our Financial Model, page 85
4.We note you now present non-GAAP financial measures you identify as Contribution
Profit (Loss) and Contribution Margin. You indicate the measures reflect direct expenses
associated with generating revenue and exclude cost of revenue, other than the creator
revenue share and third-party payment fees, that are included in GAAP gross profit.
Please address the following:
•Based on your disclosure on page 113, the costs you exclude from GAAP gross profit
to calculate these non-GAAP financial measures are "cost of revenue other than
creator revenue share and third-party payment fees, such as payroll and related
personnel expenses related to content acquisition, licensing and production".
Since you exclude normal, recurring, cash, operating expenses from these non-GAAP
financial measures, it is not clear how you determined they are appropriate and
comply with the guidance in Question 100.01 of the Division of Corporation
Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures.
•You present Contribution Margin in a graphic presentation without presenting the
most directly comparable GAAP measure, gross profit margin, with equal or greater
prominence. It is not clear how you determined your presentation complies with the
guidance in Question 102.10(a) of the Division of Corporation Finance’s
Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.

Audited Financial Statements
Note 1. Description of Business and Summary of Significant Accounting Policies
Basis of Presentation, page F-8
5.We note your disclosure regarding the revisions to your statement of cash flows for the
year ended December 31, 2023. Please explain to us how you considered the presentation
and disclosure requirements of ASC 250-10 in assessing the errors.

 FirstName LastNameJunkoo Kim
 Comapany NameWEBTOON Entertainment Inc.
 May 21, 2024 Page 3
 FirstName LastName
Junkoo Kim
WEBTOON Entertainment Inc.
May 21, 2024
Page 3
Unaudited Financial Statements
General, page F-74
6.Please provide the subsequent event disclosures, including the date through with
subsequent events were evaluated and whether that date is the date the financial
statements were issued or the date the financial statements were available to be issued,
required by ASC 855-10-50-1.

            Please contact Stephany Yang at 202-551-3167 or Anne McConnell at 202-551-3709 if
you have questions regarding comments on the financial statements and related matters. Please
contact Erin Donahue at 202-551-6063 or Evan Ewing at 202-551-5920 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing