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CORRESP
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 filename1.htm

 June 26, 2025

 Confidential

 Melissa Kindelan

 Kathleen Collins

 Mariam Mansaray

 Larry Spirgel

 Division of Corporation Finance

 Office of Technology

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 CTW Cayman

 Responses to the Staff's Comments on Amendment No. 1 to Registration
 Statement on Form F-1 Filed on June 12, 2025
 File No. 377-07710

 Ladies and Gentlemen:

 On behalf of CTW Cayman (the
" Company "), a company incorporated under the laws of the Cayman Islands, we are submitting to the staff (the " Staff ")
of the Securities and Exchange Commission (the " Commission ") this letter setting forth the Company's responses
to the comments contained in the Staff's letter dated June 24, 2025 on the Company's registration statement on Form F-1 filed
on June 12, 2025 (the " Amendment No. 1 to Registration Statement "). Concurrently with the submission of this letter,
we are filing herewith the Company's Amendment No. 2 to Registration Statement on Form F-1 (the " Amendment No. 2 to Registration
Statement ") via EDGAR to the Commission.

 In this letter, we have responded
to all of the Staff's comments by revising the Amendment No. 1 to Registration Statement to address the comments, by providing an
explanation if the Company has not so revised the Amendment No. 1 to Registration Statement, or by providing supplemental information
as requested. The Staff's comments are repeated below in bold, followed by the Company's response to such comments. We have
included page numbers to refer to the location in the Amendment No. 2 to Registration Statement where the language addressing a particular
comment appears.

 * * * *

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

 Management's Discussion and Analysis of Financial Condition and
Results of Operations

 Key Operating Metrics, page 60

 1.
 Please address the following as it related to your revised disclosure on page 14 and response to prior comment 3.

 ● Tell us, and revise to disclose, how you determine which advertising costs are specifically related
to user acquisition and the type of costs (i.e. advertising, compensation, travel, etc.) included in your calculation.

 ● Explain why you believe certain marketing costs, such as general brand marketing or promotional events,
are not relevant to attracting created users.

 ● In your response, provide us with the number of created users and advertising expense used in your
ROAS calculations for each period presented.

 ● Revise to disclose what costs are excluded from total sales and marketing expense in calculating this
measure and why.

 ● If true, revise to disclose that the cohort of created users in a particular year may not be representative of every year, and
that this measure is not indicative of past or future performance.

 Response:

 In response to the Staff's comment, the
Company has revised its methodology for calculating ROAS (Return on Advertising Spend) to include all advertising expenses incurred during
the applicable periods, without making exclusions for certain types of promotional or brand-related campaigns. This change was made to
improve consistency and comparability across reporting periods and to provide a more comprehensive view of the Company's total advertising
investment.

 Accordingly, the Company has updated the ROAS
figures as follows:

 ●
 FY2024 ROAS (updated): 99.3%

 ●
 FY2025 H1 ROAS (updated): 105.8%

 ●
 FY2024 H1 ROAS (updated): 96.6%

 ●
 FY2023 ROAS (updated): 130.3%

 The updated ROAS figures are based on the number
of created users and total advertising expenses for each period, as detailed below:

 ● FY2025 H1 :

 Created users: 16,565,252

 Advertising expenses: $24,651,703

 In-game purchases generated by created user:
$26,071,097

 ROAS = (In-game purchases generated by created
user / created user) / (advertising expenses / created user) = In-game purchases generated by created user / advertising expenses = $26,071,097
/ $24,651,703 = 105.8%

 ● FY2024 H1 :

 Created users: 8,818,514

 Advertising expenses: $16,143,247

 In-game purchases generated by created user:
$15,602,278

 ROAS = (In-game purchases generated by created
user / created user) / (advertising expenses / created user) = In-game purchases generated by created user / advertising expenses = $15,602,278
/ $16,143,247 = 96.6%

 2

 ● FY2024 :
Created users: 19,942,036

 Advertising expenses: $37,309,197

 In-game purchases generated by created
user: $37,066,685

 ROAS = (In-game purchases generated
by created user / created user) / (advertising expenses / created user) = In-game purchases generated by created user / advertising expenses
= $37,066,685 / $37,309,197 = 99.3%

 ● FY2023 :
Created users: 21,381,375

 Advertising expenses: $31,080,465

 In-game purchases generated by created
user: $40,486,035

 ROAS = (In-game purchases generated by created
user / created user) / (advertising expenses / created user) = In-game purchases generated by created user / advertising expenses = $40,486,035
/ $31,080,465 = 130.3%

 Under the revised approach, the Company includes
all expenses recorded under advertising expenses in its financial statements. These consist primarily of paid media costs for online channels
and ad placements, which are directly attributable to digital marketing efforts aimed at acquiring new users.

 The Company excludes from the ROAS calculation
the costs not classified as advertising expenses, including (i) compensation for marketing personnel, (ii) travel expenses, event-related
costs, and (iii) general overhead. These items are excluded as they are not considered advertising expenses under the Company's
accounting policies and are separately reported within the broader sales and marketing expenses line item in its financial statements.

 Historically, the Company excluded general brand
marketing and promotional events related advertising costs from ROAS calculations because they were not directly linked to attributable
user acquisition campaigns. However, under the revised methodology, all advertising spends, regardless of the type of campaign, is included
to eliminate subjectivity and improve transparency. The Company believes that this revision results in a more conservative and comprehensive
measure of advertising efficiency.

 Finally, the Company acknowledges that cohorts
of created users in any given period may not be representative of other periods, due to differences in game mix, marketing channels, and
user behavior. As such, ROAS should not be viewed as indicative of past or future performance. The Company has revised disclosure on page
26 of the Amendment No. 2 to Registration Statement to reflect this consideration.

 In response to the Staff's comment,
the Company has also revised disclosure on pages 5, 14, 60, 61, 87 and 99 of the Amendment
No. 2 to Registration Statement to reflect the revised calculation methodology and related information.

 * * * *

 3

 If you have any questions
regarding this submission, please contact Mr. Richard J. Chang at +8610 5680 3969 or rchang@gunder.com.

 Thank you again for your time
and attention.

 Yours sincerely,

 /s/ Richard J. Chang

 Richard J. Chang

 cc:
 Mr. Patrick Liu (pliu@ctw.inc), Chief Financial Officer

 CTW Cayman

 Ms. Ying Liu, Partner

 YCM CPA INC.

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