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 April 15, 2025

Hong Zhifang
Chief Executive Officer
DarkIris Inc.
13F Liberal Factory Building
3 Wing Ming Street
Cheung Sha Wan, Hong Kong

 Re: DarkIris Inc.
 Draft Registration Statement on Form F-1
 Submitted March 17, 2025
 CIK No. 0002058584
Dear Hong Zhifang:

 We have reviewed your 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.

Draft Registration Statement on Form F-1
Conventions Which Apply to this Prospectus, page ii

1. We note that you exclude Hong Kong and Macau from your definition of
PRC or
 China for the purpose of your registration statement. Please
revise to remove the
 exclusion of Hong Kong and Macau from such definition. Clarify that all
the legal and
 operational risks associated with having operations in the People s
Republic of China
 (PRC) also apply to operations in Hong Kong and Macau. In this regard,
ensure that
 your disclosure does not narrow risks related to operating in the PRC to
mainland
 China only. Where appropriate, you may describe PRC law and then explain
how law
 in Hong Kong and Macau differs from PRC law and describe any risks and
 consequences to the company associated with those laws.
 April 15, 2025
Page 2

Prospectus Summary, page 1

2. We note your statement that you "have not . . . independently verified"
 publications conducted by third party market research companies, and
investors are
 "cautioned not to give undue weight to such data and estimates." Such
statement may
 imply an inappropriate disclaimer of liability for such third-party
information. Please
 revise to remove any implication that investors are not entitled to rely
on information
 in your registration statement.
Risk Factors
We will be a "controlled company" within the meaning of the Nasdaq Stock Market
Rules...,
page 43

3. Please briefly describe the corporate governance requirements that you
will not be
 required to comply with as a controlled company.
Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 50

4. We note your reference on page 21 that you "track certain performance
metrics,
 including the number of active and paying gameplayers of [y]our games."
Please
 revise to include a discussion of your key operating metrics that
management uses to
 manage the business and that would be material to investors. Refer to
Section III.B of
 SEC Release No. 33-8350.
Capital Needs, page 52

5. Please revise to separately analyze your ability to generate and obtain
adequate
 amounts of cash to meet your requirements and your plans for cash in the
long-term
 (i.e., beyond the next 12 months). Refer to Item 5.B. of Form 20-F.
Business
Our Products, page 60

6. We note your disclosure on page 13 that "two licensed games, The
Great Story of
 Wei, Shu, and Wu and Myth of the Floating Sky contributed
approximately 62%
 and 53% of [y]our total gross revenue for the fiscal years ended
September 30, 2024
 and 2023, respectively." We are unable to locate any additional
information pertaining
 to the "Myth of the Floating Sky." Please revise your disclosure to
include material
 information related to the "Myth of the Floating Sky," such as revenue
from in-game
 purchases, total gameplayers, and monthly download volume.
 April 15, 2025
Page 3
Our Major Suppliers, page 67

7. We note that you depend on a small number of suppliers and that four
suppliers
 accounted for 48%, 12%, 12%, and 12% of your total cost of revenue for
the fiscal
 year ended September 30, 2024 and that three suppliers accounted for
50%, 19%, and
 13% of your cost of revenue for the fiscal year ended September 30,
2023. Please
 revise here to identify your largest supplier and disclose the material
terms of any
 material agreements with this supplier. See Item 3.D and Item 4.B of
Form 20-F.
 Additionally, please file any material agreements as exhibits. Refer to
Item
 601(b)(10)(ii)(B) of Regulation S-K.
Principal Shareholders, page 92

8. Please revise to identify the natural person or persons who exercise the
voting and/or
 dispositive powers with respect to the securities owned by Vertex
International
 Capital Ltd and Topbest International Capital Ltd.
General

9. Please supplementally provide us with copies of all written
communications, as
 defined in Rule 405 under the Securities Act that you, or anyone
authorized to do so
 on your behalf, present to potential investors in reliance on Section
5(d) of the
 Securities Act, whether or not they retain copies of the communications.

 Please contact Morgan Youngwood at 202-551-3479 or Stephen Krikorian at
202-
551-3488 if you have questions regarding comments on the financial statements
and related
matters. Please contact Marion Graham at 202-551-6521 or Jeff Kauten at
202-551-3447 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Lawrence Venick
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