SecProbe.io

CORRESP
 1
 filename1.htm

 Try
Hard Holdings Limited

 541-0056,
2 Chome 5-19

 Kyutaromachi

 Chuo
Ward, Osaka

 Japan

 November
25, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention:

 Kate
 Beukenkamp

 Division
 of Corporate Finance

 Re:
 TryHard
 Holdings Limited

 Registration
 Statement on Form F-1, as amended (File No. 333-291238)

 Request for Acceleration
 of Effectiveness

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended (the "Securities Act"), TryHard Holdings Limited, a
Cayman Islands company (the "Company"), respectfully requests that the effective date of its Registration Statement on Form
F-1 (File No. 333-291238) (the "Registration Statement"), be accelerated so that it will become effective at 3:00
p.m., Eastern Time, Wednesday, November 26, 2025, or as soon thereafter as possible.

 In
making this acceleration request, the Company acknowledges that:

 (i)
 should the Securities and
 Exchange Commission (the "Commission") or the staff, acting pursuant to delegated authority, declare the Registration
 Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

 (ii)
 the action of the Commission
 or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company
 from its full responsibility for the adequacy of the disclosure in the Registration Statement; and

 (iii)
 the Company may not assert
 comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding
 initiated by the Commission or any person under the federal securities laws of the United States.

 Once
the Registration Statement is effective, please orally confirm the event with our counsel, TroyGould PC by calling Joilene Wood at (415)
305-4651 or David Ficksman at (310) 789-1290. We also respectfully request that a copy of the written order from the Commission verifying
the effective time and date of the Registration Statement be sent to our counsel, TroyGould PC, Attention: David Ficksman, by facsimile
to (310) 789-1290 or email at dficksman@troygould.com.

 If
you have any questions regarding this request, please contact Joilene Wood at (415) 305-4651.

 Very truly
 yours,

 By:
 /s/
 Rakuyo Otsuki

 Name:
 Rakuyo Otsuki

 Title:
 Chief Executive Officer
 & Executive Director

 cc:
 David Ficksman, TroyGould
 PC

 R. Joilene Wood, TroyGould
 PC