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TryHard
Holdings Ltd

541-0056,
2 Chome 5−19

Kyutaromachi

Chuo
Ward, Osaka

Japan

August
5, 2025

Via
EDGAR

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C., 20549

    Re:
    TryHard
    Holdings Ltd

    Registration
    Statement Form F-1, as amended

    File
    No. 333-287751

Ladies
and Gentlemen:

We
note the comment received from the U.S. Securities and Exchange Commission (the “Commission”) dated August 1, 2025 to Amendment
No. 2 to the Registration Statement on Form F-1 submitted on July 21, 2025. We have revised the Registration Statement on Form F-1, filed
herewith as Amendment No. 3. Please see our response to your comment, which we have restated below.

Amendment
No. 2 to Registration Statement on Form F-1

Index
to Consolidated Financial Statements, page F-1

    1.

    We
    note your filing includes audited financial statements that are older than 12 months. Please update your financial statements in
    accordance with Item 8.A.4 of Form 20-F or include the representation noted in Instruction 2 to Item 8.A.4 as an exhibit to your
    registration statement.

We
have attached a Waiver and Representation letter in accordance with Item 8.A.4 as Exhibit 99.3. We also have provided all outstanding
exhibits and an updated consent of auditor.

If
you have any questions regarding the Registration Statement on Form F-1 filed herewith, please direct them to our counsel David Ficksman
at 310-789-1290 or dficksman@troygould.com or Joilene Wood at 415-305-4651 or jwood@troygould.com.

    Sincerely,

    TryHard
    Holdings Ltd

    By:
    /s/
    Rakuyo Otsuki

    Rakuyo
    Otsuki

    Chief
    Executive Officer

    cc:
    David
    L. Ficksman

    R.
    Joilene Wood