SecProbe.io

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 September 26, 2025

In Keuk Kim
Chief Executive Officer
DoubleDown Interactive Company, Limited
13F, Gangnam Finance Center
152, Teheran-ro Gangnam-gu
Seoul 06236, Republic of Korea

 Re: DoubleDown Interactive Company, Limited
 Registration Statement on Form F-3
 Filed September 19, 2025
 File No. 333-290402
Dear In Keuk Kim:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rule 461 regarding requests for acceleration. We remind
you that the
company and its management are responsible for the accuracy and adequacy of
their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Marion Graham at 202-551-6521 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Barbara Jones
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 DOUBLEDOWN INTERACTIVE CO., LTD.
 13F, Gangnam Finance Center
 152, Teheran-ro Gangnam-gu
 Seoul 06236, Republic of Korea
 September 26, 2025 VIA EDGAR
 U.S. Securities and Exchange Commission Division of Corporation
Finance Office of Technology 100 F Street N.E.
 Washington, D.C. 20549

 Re:
 DoubleDown Interactive Co., Ltd.
 Registration Statement on Form F-3
 File No. 333-290402
 Request for Acceleration of Effectiveness
 Ladies and Gentlemen: Pursuant to Rule 461
promulgated under the Securities Act of 1933, as amended (the “ Securities Act ”), DoubleDown Interactive Co., Ltd., a foreign private issuer organized under the laws of the Republic of Korea (the “ Company ”),
hereby respectfully requests acceleration of the effective date of the above-referenced Registration Statement on Form F-3 (File No. 333-290402) (as amended, the
“ Registration Statement ”), so that such Registration Statement shall become effective at 4:00 p.m., Eastern Time, on Tuesday, September 30, 2025, or as soon thereafter as practicable.
 The Company understands that the Securities and Exchange Commission will consider this request for acceleration of the effective date of the
Registration Statement as a confirmation of the fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed public offering of the securities specified in the Registration Statement.
 If there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the
Company may be making an oral request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461. Such request may be made by an executive officer of the Company or by an attorney from the Company’s external
counsel, Greenberg Traurig, LLP. If you have any questions regarding the foregoing, please contact our counsel, Barbara A. Jones of
Greenberg Traurig, LLP at (310) 586-7773 or by email at Barbara.Jones@gtlaw.com. In addition, it would be greatly appreciated if you could please call Ms. Jones to notify her when the Registration
Statement has been declared effective.

 Very truly yours,

 D OUBLE D OWN I NTERACTIVE C O ., L TD .

 By:

 /s/ Joseph A. Sigrist

 Name: Joseph A. Sigrist

 Title: Chief Financial Officer

 cc:
 In Keuk Kim, Chief Executive Officer, DoubleDown Interactive Co., Ltd.
 Barbara A. Jones, Esq., Greenberg Traurig, LLP

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 DOUBLEDOWN INTERACTIVE CO., LTD.

13F, Gangnam Finance Center

152, Teheran-ro Gangnam-gu

Seoul 06236, Republic of Korea

September 23, 2022

 VIA EDGAR

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street N.E.

 Washington, D.C. 20549

Attn: Priscilla Dao

 Jan Woo

Re:
 DoubleDown Interactive Co., Ltd.

Registration Statement on Form F-3

File No. 333-267422

Request for Acceleration of Effectiveness

Ladies and Gentlemen:

 Pursuant to Rule 461
promulgated under the Securities Act of 1933, as amended (the “Securities Act”), DoubleDown Interactive Co., Ltd., a foreign private issuer organized under the laws of the Republic of Korea (the “Company”), hereby
respectfully requests acceleration of the effective date of the above-referenced Registration Statement on Form F-3 (File No. 333-267422) (as amended, the
“Registration Statement”), so that such Registration Statement shall become effective at 4:00 p.m., Eastern Time, on Tuesday, September 27, 2022, or as soon thereafter as practicable.

The Company acknowledges the following:

•

 should the U.S. Securities and Exchange Commission (the “Commission”) or the staff, acting
pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

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

•

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

 If you have any
questions regarding the foregoing, please contact our counsel, Barbara A. Jones of Greenberg Traurig, LLP at (310) 586-7773 or by email at jonesb@gtlaw.com. In addition, it would be greatly appreciated if you
could please call Ms. Jones to notify her when the Registration Statement has been declared effective.

Very truly yours,

DOUBLEDOWN INTERACTIVE CO., LTD.

By:

/s/ In Keuk Kim

Name: In Keuk Kim

Title: Chief Executive Officer

cc:
 Joseph A. Sigrist, Chief Financial Officer, DoubleDown Interactive Co., Ltd.

Barbara A. Jones, Esq., Greenberg Traurig, LLP

Eun Sang Hwang, Esq., Greenberg Traurig, LLP

United States securities and exchange commission logo
September 20, 2022
Joseph Sigrist
Chief Financial Officer
DoubleDown Interactive Co., Ltd.
13F, Gangnam Finance Center
152, Teheran-ro Gangnam-gu
Seoul 06236, Republic of Korea
Re:DoubleDown Interactive Co., Ltd.
Registration Statement on Form F-3
Filed September 14, 2022
File No. 333-267422
Dear Mr. Sigrist:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Priscilla Dao, Staff Attorney, at (202) 551-5997 or Jan Woo, Legal Branch
Chief, at (202) 551-3453 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Barbara A. Jones

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 DOUBLEDOWN INTERACTIVE CO., LTD.

13F, Gangnam Finance Center

152, Teheran-ro Gangnam-gu

Seoul 06236, Republic of Korea

August 26, 2021

 VIA EDGAR

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street N.E.

 Washington, D.C. 20549

Attention:
 Mr. Larry Spirgel

Ms. Kathryn Jacobson

Mr. Robert Littlepage

Mr. Jeff Kauten

Re:
 DoubleDown Interactive Co., Ltd.

Registration Statement on Form F-1 (File
No. 333-258032)

 Request for Acceleration of Effectiveness

Ladies and Gentlemen:

 In accordance with Rule
461 under the Securities Act of 1933, as amended (the “Securities Act”), DoubleDown Interactive Co., Ltd., a foreign private issuer organized under the laws of the Republic of Korea (the “Company”), hereby requests
acceleration of the effective date of the above-referenced Registration Statement on Form F-1, File No. 333-258032 (as amended, the “Registration
Statement”), so that such Registration Statement shall become effective at 4:00 p.m. (EDT) on August 30, 2021, or as soon thereafter as practicable. Once the Registration Statement has been declared effective, please orally confirm that
event with our counsel, Greenberg Traurig, LLP., by calling Barbara A. Jones, Esq. at 310.586.7773.

 The Company acknowledges the
following:

•

 should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does
not foreclose the Commission from taking any action with respect to the filing;

•

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

•

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

Very truly yours,

DOUBLEDOWN INTERACTIVE CO., LTD.

By:

 /s/ In Keuk Kim

Name:

In Keuk Kim

Title:

Chief Executive Officer

cc:
 Joseph A. Sigrist, Chief Financial Officer, DoubleDown Interactive Co., Ltd.

Barbara A. Jones, Esq., Greenberg Traurig, LLP

Eun Sang Hwang, Esq., Greenberg Traurig, LLP

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 August 26, 2021

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 DoubleDown Interactive Co., Ltd. Registration Statement on Form –
F-1 (Registration No. 333-258032)

 Ladies and
Gentlemen:

 In connection with the above-referenced Registration Statement, as amended, and pursuant to Rule 461 under the Securities Act of 1933, as
amended (the “Act”), we hereby join in the request of DoubleDown Interactive Co., Ltd. that the effective date of the Registration Statement, as amended, be accelerated so that it will be declared effective at 4:00 p.m. Eastern Time
on August 30, 2021, or as soon thereafter as practicable.

 Pursuant to Rule 460 under the Act, please be advised that we have distributed
approximately 840 copies of the preliminary prospectus dated August 20, 2021 through the date hereof, to underwriters, dealers, institutions and others.

In connection with the preliminary prospectus distribution for the above-referenced issue, the prospective underwriters have confirmed that they are complying
with the 48-hour requirement in Rule 15c2-8(b) under the Securities Exchange Act of 1934, as amended.

Very truly yours,

 B. RILEY SECURITIES, INC.

As Representative of the several underwriters

[SIGNATURE PAGES FOLLOW]

B. RILEY SECURITIES, INC.

By:

/s/ Jimmy Baker

Name: Jimmy Baker

Title: President

 As representative of the several underwriters.

cc:

 Jeeho Lee

Tai Vivatvaraphol

 [Signature Page to
Acceleration Request Letter]

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 August 20, 2021

VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, N.E.

Washington, D.C. 20549

Attn:
 Mr. Larry Spirgel

Ms. Kathryn Jacobson

Mr. Robert Littlepage

Mr. Jeff Kauten

Re:
 DoubleDown Interactive Co., Ltd.

Staff Comment Letter, dated August 5, 2021, in connection with

Registration Statement on Form F-1, filed on July 20, 2021

File No. 333-258032

Ladies and Gentlemen:

 This letter is submitted
on behalf of DoubleDown Interactive Co., Ltd., a foreign private issuer organized under the laws of the Republic of Korea (the “Company”), in response to the comments of the staff of the Division of Corporation Finance (the
“Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the Company’s Registration Statement on Form F-1 (the “Registration
Statement”) filed with the Commission on July 20, 2021, as set forth in your letter dated August 5, 2021 addressed to Mr. In Keuk Kim, Chief Executive Officer of the Company (the “Comment Letter”). The
Company is concurrently submitting to the Commission electronically via EDGAR, the Amendment No. 1 to the Registration Statement on Form F-1 (the “Amendment No. 1”),
which includes changes that reflect responses to the Staff’s comments, and certain other updates, including the financial results and financial statements of the Company for the six months ended June 30, 2021 and 2020.

As advised by the Staff in light of the COVID-19-related
workplace issues, we are not at this time separately delivering to the Commission for the Staff’s reference hard copies of the Amendment No. 1 and the exhibits filed therewith, but will of course do so in the future if and when the Staff
considers appropriate.

 The Company currently intends to proceed with the offering in the near future, subject to market conditions and
other considerations. The Company advises the Staff that submission of requests for acceleration pursuant to Rules 460 and 461 will be made in due course.

The headings and numbered paragraphs of this letter correspond to the same contained in the Comment Letter, and to facilitate your review, the
text of the Comment Letter has been reproduced herein, followed by the Company’s response to each comment. Unless otherwise indicated, page references in the descriptions of the Staff’s comments refer to the Registration Statement, and
page references in the Company’s responses refer to the Amendment No. 1.

 GREENBERG TRAURIG, LLP ∎ ATTORNEYS
AT LAW ∎ WWW.GTLAW.COM

 1840 Century Park East, Suite 1900 ∎ Los Angeles, California 90067-2121 ∎ Tel 310.586.7700 ∎ Fax
310.586.7800

 U.S. Securities and Exchange Commission

August 20, 2021

  Page
 2

 Registration Statement on Form F-1

Notes to Condensed Consolidated Financial Statements (Unaudited)

Note 10. Commitments and Contingencies, page F-39

1.
 Regarding the Benson case (cited on page 97 and unnamed hereunder), we note that no amount has been recorded in
connection with the lawsuit. However, on page 98, you stated that if we were to settle the Benson lawsuit at this time ... such settlement would likely be for a significant monetary amount and our operating results and financial condition could be
materially adversely affected. In this regard, you indicated that similar class actions have finalized settlements in amounts ranging up to $155 million (page 97). You further disclosed on page 98 that your insurer will not cover such expenses
or any losses that could arise for any settlement amount or damages award in this particular case. In view of a court order for the parties to settle, material legal settlements in precedent cases, absent any insurance coverage nor indemnification
from your codefendant, please tell us why you did not accrue a loss in your financial statements. It appears that a loss is probable and reasonably estimable based on your statement on page 98 that prior to the resolution of the Benson case, we may
be required, or otherwise deem it advisable, to record a material financial reserve in respect of a potential adverse outcome. Refer to ASC
450-20-25-2 through 25-5.

Response to Comment No. 1:

The Company thanks the Staff for its comment and respectfully advises the Staff that, as required, it performs an analysis under the provisions
of ASC 450-20 on a quarterly basis.

 In performing such quarterly assessment as to whether it is
probable that a liability will be incurred in connection with the Benson matter, management considered, among other things: (a) the merit of the claims in the litigation, including jurisdictional challenges, (b) procedural
developments since the date of the last financial statements, including the status and nature of discovery, new motions, rulings on the merits, whether a class has been certified, and the nature and extent thereof, if any, (c) relevant
precedent, including settled and pending similar cases together with distinguishing features thereof compared to Benson, (d) opinions and views of legal counsel and other advisors, (e) updates to the Company’s litigation
approach and strategy, (f) the extent to which any settlement discussions have occurred and the substance of any such discussions, (g) the likelihood of a settlement as an outcome, (h) available defenses and counterclaims,
(i) the status of discussions with co-defendants on strategy and indemnification, and (j) the possibility of an unfavorable outcome and the impact on the Company’s business.

In connection with management’s assessment of developments in the case to date and the preparation of the unaudited consolidated financial
statements for the period ended June 30, 2021, management has deemed it appropriate, consistent with the applicable accounting principles and in light of all the current facts and circumstances as of the date of the financial statements, to
recognize a liability for this loss contingency. This liability represents management’s estimate of the low end of the range of reasonably possible loss. However, the Company may experience a loss in excess of the liability recorded, which
could be material. Management’s estimate of reasonably possible range of loss is $3.5 million to $201.5 million; however, the ultimate outcome cannot be known at this time due to the significant incomplete, uncertain, and unknown variables
inherent with this stage of the pending litigation. In measuring such liability, management evaluated the factors set out above, together with other assumptions, all of which involve a series of complex judgments about potential future events with
multiple outcomes. The Company has recorded a charge to income under General & Administrative Expenses in the Company’s unaudited consolidated financial statements for the quarter ended June 30, 2021, which are included in
Amendment No. 1 beginning on page F-27. The Company also refers the Staff to the disclosure below for Note 10 to such financial statements and changes to disclosure in the forepart of Amendment
No. 1.

 The Company has included the following disclosure in Note 10: Commitments and contingencies—Legal contingencies:

“The case is subject to significant uncertainties. In determining the likelihood of a loss and/or the measurement of any loss or range of
loss, we evaluated (1) the facts and circumstances known to us, including information regarding the likelihood of a settlement and the outcome of discussions relating to indemnification by co-defendants,
(2) the current state of the proceedings, including outstanding motions for certification of a class, or denial thereof, and other relevant events and developments, (3) the advice and analyses of counsel and other advisors, and
(4) the assumptions and judgment of management, all of which involve a series of complex judgments about potential future events with multiple outcomes. In accordance with ASC 450-20, the Company has
recorded a charge to income for this loss contingency during the period ended June 30, 2021, which is included in General and Administrative Expenses, reflecting the low end of the reasonably possible range of loss of $3.5 million to
$201.5 million. The Company will continue to evaluate the appropriateness of the amount recorded as the litigation proceeds over time, potentially resulting in a material adjustment thereto.”

 U.S. Securities and Exchange Commission

August 20, 2021

  Page
 3

 In addition, the Company has revised its disclosure on pages
17-18 under “Risk Factors” and on pages 97-98 under “Business—Legal Proceedings” as follows to minimize potential confusion:

“In connection with the Benson case, IGT tendered us its defense of the lawsuit and sought indemnity from us and certain of our
affiliates for any damages from the lawsuit, based on various agreements associated with IGT’s sale of DDI-US to us. We had previously tendered IGT our defense and sought indemnity from it. The parties
have entered into a standstill or tolling agreement, which expires on or before September 1, 2021. There can be no guarantee, however, that we will be able to secure indemnification for any damages from the lawsuit.

We have incurred and expect to continue to incur significant expense defending the Benson lawsuit, and we may incur in the future
significant expense with respect to any other lawsuits to which we may become a party. In general, subject to certain terms and conditions, insurance coverage for our litigation expenses and losses arising out of legal proceedings is assessed by our
insurers on a case by case basis and there can be no guarantee that coverage will be available in any particular case. However, in connection with the Benson lawsuit, our insurer will not cover such expenses or any losses that could arise for
any settlement amount or damages award.

 The resolution of the Benson lawsuit, whether through the court or through settlement,
could have a material adverse effect on our operating results and financial condition. As set out in Note 10 to the unaudited consolidated financial statements for the period ended June 30, 2021, the Company has recorded a charge to income for
this litigation, which is included in general and administrative expenses. However, the Company may experience a loss in excess of the amount recorded, which could be material; the ultimate outcome cannot be known at this time due to the
significant incomplete, uncertain, and unknown variables inherent with this stage of the pending litigation. The amount recorded represents management’s estimate, in accordance with applicable accounting standards, of the low end of the
reasonably possible range of loss of $3.5 million to $201.5 million. Management will continue to evaluate the reasonably possible range of loss and the amount recorded as the litigation proceeds over time, potentially resulting in a
material adjustment thereto. As noted above, our operating results and financial condition could be materially adversely impacted by the resolution of the Benson case. We continue to dispute any allegation of wrongdoing and we intend to
continue our vigorous defense in this matter. There can be no guarantee that we will be able to recover all or any part of any damages award or, if applicable, settlement amount, or obtain a contribution with respect thereto, from any other
defendant. Additionally, there can be no guarantee as to what, if any, additional modifications any judgments or settlements might impose on one or more of our games.”

Supplementally, for the sake of clarity, the Company also wishes to respond to the statement in Comment 1, where the Staff states, in relevant
part, “In view of a court order for the parties to settle, material legal settlements in precedent cases, absent any insurance coverage nor indemnification from your co-defendants...”

•

 First, the Company advises that there is no “court order for the parties to settle.” There is a court
order to hold a settlement conference by September 7, 2021, which is a standard procedure in the progress of a litigation matter in advance of trial. At this time, no trial date has been set. The Company considers the probability of a
settlement arising out of a settlement conference to be remote, as the Company is defending the case vigorously and has no intention at this stage of the proceedings to settle.

•

 Second, with respect to the “material legal settlements,” each of the three precedents has had a
different result based upon the facts and circumstances of their particular situations, with settlements in the amount of $6.5 million, $38.0 million, and $155.0 million. Two of the cases were limited to a Washington class and one was a
national class. The size of the class is a key factor in considering the potential impact of an adverse outcome at trial or to settlement negotiations. The facts and circumstances of our case could result in materially different outcomes. In
addition, there are other pending cases with some similarities to Benson in which there has been no settlement or trial on the merits, the outcome of which could also influence the Company’s assessment. Further, discovery in the
Benson case is continuing. Thus, while we are following developments in these cases closely, and disclose them to provide investors for additional context, our intent is not to suggest that the facts are similar to the extent that the
settlements that have occurred necessarily directly affect our evaluation.

•

 Third, as noted above, the availability of any indemnification has not yet been determined with co-defendants and the issue remains open. Although an indemnification agreement would not be considered for purposes of the amount of charge taken against income in accordance with ASC
450-20, the availability thereof can contribute to the Company’s overall defense strategy and could influence the timing and magnitude of any settlement discussions that may occur in the future.

 U.S. Securities and Exchange Commission

August 20, 2021

  Page
 4

2.
 We understand that Hanover Insurance Co. had filed a declaratory judgment action alleging that its insurance
policy does not cover the claims made by NEXRF Corp. in its patent infringement suit. On page 98, you stated that due to the early nature of this case, it is not possible to assess whether this case may be material to your business. Notwithstanding,
in light of the reasonable possibility that a loss may have been incurred, please disclose the amount of the settlement demand made by NEXRF Corp. Refer to ASC 450-20-50-3 through 50-4.

Response to Comment No. 2:

The Company respectfully advises the Staff that the amount of settlement demand made by NEXRF Corp. was $7.5 million. The Company has
accordingly disclosed such amount of settlement demand on pages 18 and 97 and in Note 10: Commitment and Contingencies of the notes to its unaudited consolidated financial statements for the six months ended June 30, 2021 and 2020 on page F-42
in response to the Staff’s comment.

 General, page F-41

3.
 Please include a footnote on subsequent events disclosing your evaluation of the effects of all subsequent
events through the date the financial statements were issued. Refer to ASC 855-10-25-1.

Response to Comment No. 3:

The Company has added Note 13: Subsequent Events to its unaudited condensed consolidated statements for the six months ended June 30, 2021
and 2020 on page F-43 in response to the Staff’s comment.

4.
 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.

Response to Comment No. 4:

The Company respectfully advises the Staff that it submitted copies of the written communications present to potential investors,
electronically via secur

United States securities and exchange commission logo
August 5, 2021
In Keuk Kim
Chief Executive Officer
DoubleDown Interactive Co., Ltd.
13F, Gangnam Finance Center
152, Teheran-ro Gangnam-gu
Seoul 06236, Republic of Korea
Re:DoubleDown Interactive Co., Ltd.
Registration Statement on Form F-1
Filed July 20, 2021
File No. 333-258032
Dear Mr. Kim:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-1
Notes to Condensed Consolidated Financial Statements (Unaudited)
Note 10. Commitments and Contingencies, page F-39
1.Regarding the Benson case (cited on page 97 and unnamed hereunder), we note that no
amount has been recorded in connection with the lawsuit.  However, on page 98, you
stated that  "if we were to settle the Benson lawsuit at this time ... such settlement would
likely be for a significant monetary amount and our operating results and financial
condition could be materially adversely affected."  In this regard, you indicated that
similar class actions have finalized settlements in amounts ranging up to $155 million
(page 97). You further disclosed on page 98 that your insurer will not cover such expenses
or any losses that could arise for any settlement amount or damages award in this

 FirstName LastNameIn Keuk Kim
 Comapany NameDoubleDown Interactive Co., Ltd.
 August 5, 2021 Page 2
 FirstName LastNameIn Keuk Kim
DoubleDown Interactive Co., Ltd.
August 5, 2021
Page 2
particular case.  In view of a court order for the parties to settle, material legal settlements
in precedent cases, absent any insurance coverage nor indemnification from your co-
defendant, please tell us why you did not accrue a loss in your financial statements.  It
appears that a loss is probable and reasonably estimable based on your statement on page
98 that "prior to the resolution of the Benson case, we may be required, or otherwise deem
it advisable, to record a material financial reserve in respect of a potential adverse
outcome."  Refer to ASC 450-20-25-2 through 25-5.
2.We understand that Hanover Insurance Co. had filed a declaratory judgment action
alleging that its insurance policy does not cover the claims made by NEXRF Corp. in its
patent infringement suit.  On page 98, you stated that due to the early nature of this case, it
is not possible to assess whether this case may be material to your business.
Notwithstanding, in light of the reasonable possibility that a loss may have been
incurred, please disclose the amount of the settlement demand made by NEXRF Corp.
Refer to ASC 450-20-50-3 through 50-4.
General, page F-41
3.Please include a footnote on subsequent events disclosing your evaluation of the effects of
all subsequent events through the date the financial statements were issued.  Refer to ASC
855-10-25-1.
4.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.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

 FirstName LastNameIn Keuk Kim
 Comapany NameDoubleDown Interactive Co., Ltd.
 August 5, 2021 Page 3
 FirstName LastName
In Keuk Kim
DoubleDown Interactive Co., Ltd.
August 5, 2021
Page 3
            You may contact Kathryn Jacobson, Senior Staff Accountant, at (202) 551-3365 or
Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact Jeff Kauten, Staff
Attorney, at (202) 551-3447 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Barbara A. Jones, Esq.

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June 25, 2020

Via EDGAR

Securities and Exchange Commission

100 F Street, N.W.

Washington, D.C. 20549

    Attention:

    Corey Jennings, Esq.

Office of International Corporate Finance

Division of Corporate Finance

    Re:

    DoubleDown Interactive Co., Ltd.

Registration Statement on Form F-6 (Registration
No.: 333-239022)

Dear Mr. Jennings:

Citibank N.A., as depositary (the “Depositary”)
and acting solely on behalf of the legal entity created by the Deposit Agreement, by and among the Depositary, DoubleDown Interactive
Co., Ltd., a company organized under the laws of the Republic of Korea (the “Company”), and all Holders and Beneficial
Owners of American Depositary Shares issued thereunder representing the Company’s common shares of the Company, hereby requests
that the effectiveness of Registration Statement on Form F-6, as amended by Pre-Effective Amendment No. 1 to Registration Statement
on Form F-6 (Registration No.: 333-239022), be accelerated to coincide with the accelerated effectiveness of the Company’s
Registration Statement on Form F-1, as amended (Registration No.: 333- 238884).

Please call me at (212) 816-7937 if you have
any questions.

    Very truly yours,

    CITIBANK, N.A.

    By:
    /s/ Leslie A. DeLuca

    Name:
    Leslie A. DeLuca

    Title:
    Attorney-in-Fact

cc:	Herman H. Raspé, Esq. (Patterson, Belknap, Webb
& Tyler LLP)

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 DOUBLEDOWN INTERACTIVE CO., LTD.

13F, Gangnam Finance Center

152, Teheran-ro Gangnam-gu

Seoul 06236, Republic of Korea

June 25, 2020

 VIA EDGAR

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street N.E.

 Washington, D.C. 20549

Attention: Ms. Kathryn Jacobson

Mr. Craig Wilson

Mr. Jeff Kauten

Ms. Kathleen Krebs

Re:
 DoubleDown Interactive Co., Ltd.

Registration Statement on Form F-1 (File
No. 333-238884)

 Registration Statement on Form
8-A (File No. 001-39349)

 Registration
Statement on Form F-6 (File No. 333-239022)

Request for Acceleration of Effectiveness

Ladies and Gentlemen:

 In accordance with Rule
461 under the Securities Act of 1933, as amended (the “Securities Act”), DoubleDown Interactive Co., Ltd., a foreign private issuer organized under the laws of the Republic of Korea (the “Company”), hereby requests
acceleration of the effective date of the above-referenced Registration Statement on Form F-1 (File No. 333-238884), and the corresponding Registration Statement on
Form 8-A (File No. 001-39349), so that such Registration Statements shall become effective at 12:00 p.m. (EDT) on June 30, 2020, or as soon thereafter as
practicable. Once the Registration Statements have been declared effective, please orally confirm that event with our counsel, Greenberg Traurig, LLP., by calling Barbara A. Jones, Esq. at 310.586.7773.

The Company also joins a request that is concurrently being filed by Citibank, N.A. requesting that the Company’s Registration Statement
on Form F-6 (File No. 333-239022) be declared effective simultaneously with the Registration Statement on Form F-1. The
Company intends to commence trading in the Company’s ADSs on or about July 1, 2020 on the Nasdaq Global Select Market.

 The
Company acknowledges the following:

•

 should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does
not foreclose the Commission from taking any action with respect to the filing;

•

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

•

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

 Very truly yours,

 DOUBLEDOWN INTERACTIVE CO., LTD.

By:

 /s/ In Keuk Kim

 Name: In Keuk Kim

 Title: Chief Executive Officer

 cc:     Joseph A. Sigrist, Chief Financial Officer, DoubleDown Interactive Co., Ltd.

Barbara Jones, Esq., Greenberg Traurig, LLP

Iksoo Kim, Esq., Greenberg Traurig, LLP

CORRESP
1
filename1.htm

CORRESP

 J.P. Morgan Securities LLC

383 Madison Avenue

 New York, NY 10179

BofA Securities, Inc.

 One Bryant Park

New York, NY 10036

 Macquarie Capital (USA) Inc.

125 W 55th St, 22nd Floor

 New York, NY 10019

June 25, 2020

 VIA EDGAR CORRESPONDENCE AND
FACSIMILE

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-7561

Attn:

Ms. Kathryn Jacobson

Mr. Craig Wilson

Mr. Jeff Kauten

Ms. Kathleen Krebs

Re:

DoubleDown Interactive Co., Ltd.

Registration Statement on Form F-1, as amended (File No. 333-238884)

Registration Statement on Form 8-A (File No. 001-39349)

 Ladies and Gentlemen:

We hereby join DoubleDown Interactive Co., Ltd. (the “Company”) in connection with its request for acceleration of the
above-referenced Registration Statements, requesting effectiveness at 12:00 p.m. (EDT) on June 30, 2020, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act of 1933, as amended, we wish to
advise you that, through the date hereof, approximately 797 copies of the Company’s preliminary prospectus were distributed to prospective underwriters, institutional investors, dealers and others.

The undersigned advise that the underwriters have complied and will continue to comply with
Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 [Signature
page follows]

By:

J.P. MORGAN SECURITIES LLC

By:

/s/ Paul Mule

Name:

Paul Mule

Title:

Executive Director

By:

BOFA SECURITIES, INC.

By:

/s/ Michele Allong

Name:

Michele Allong

Title:

Authorized Signatory

By:

MACQUARIE CAPITAL (USA) INC.

By:

/s/ Sung Chun

Name:

Sung Chun

Title:

Senior Managing Director

By:

/s/ Sam Kim

Name:

Sam Kim

Title:

Senior Vice President

CORRESP
1
filename1.htm

CORRESP

 June 18, 2020

FOIA CONFIDENTIAL TREATMENT REQUESTED UNDER

17 U.S.C. SECTION 200.83

BY DOUBLEDOWN INTERACTIVE CO., LTD.

SUBMISSION VIA EDGAR

 U.S. Securities and
Exchange Commission

 Division of Corporation Finance

 100 F.
Street, N.E.

 Washington, D.C. 20549

Attn:
 Ms. Kathryn Jacobson

Mr. Craig Wilson

Mr. Jeff Kauten

Ms. Kathleen Krebs

Re:
 DoubleDown Interactive Co., Ltd.

Staff Comment Letter, dated June 12, 2020, in connection with

Registration Statement on Form F-1, filed June 2, 2020

File No. 333-238884

Ladies and Gentlemen:

 This letter is submitted
on behalf of DoubleDown Interactive Co., Ltd., a foreign private issuer organized under the laws of the Republic of Korea (the “Company”), in response to the comments of the staff of the Division of Corporation Finance (the
“Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the Company’s Registration Statement on Form F-1 (File No. 333-238884) (as amended, the “Registration Statement”), filed with the Commission on June 2, 2020, as set forth in your letter dated June 12, 2020 addressed to Mr. In Keuk
Kim, Chief Executive Officer of the Company (the “Comment Letter”).

 The Company is concurrently submitting to the
Commission, electronically via EDGAR, the Amendment No. 1 to Registration Statement on Form F-1 (the “Amendment No. 1”), which includes changes that reflect responses
to the Staff’s comments. As advised by the Staff in light of the COVID-19-related workplace issues, we are not at this time separately delivering to the Commission
for the Staff’s reference hard copies of the Amendment No. 1 and the exhibits filed therewith, but will of course do so in the future if and when the Staff considers appropriate.

GREENBERG TRAURIG, LLP ∎ ATTORNEYS AT LAW ∎ WWW.GTLAW.COM

1840 Century Park East, Suite 1900 ∎ Los Angeles, California 90067-2121 ∎ Tel 310.586.7700 ∎ Fax 310.586.7800

 CONFIDENTIAL TREATMENT REQUESTED BY DOUBLEDOWN INTERACTIVE CO., LTD.

U.S. Securities and Exchange Commission

 June 18, 2020

 Page
 2

 The Company notes the Staff’s comment regarding submission of requests for acceleration
pursuant to Rules 460 and 461.

 The headings and numbered paragraphs of this letter correspond to the same contained in the Comment
Letter, and to facilitate your review, the text of the Comment Letter has been reproduced herein, followed by the Company’s response to each comment. Unless otherwise indicated, page references in the descriptions of the Staff’s comments
refer to the Amendment No.1.

 Registration Statement on Form F-1

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

Our marketing efficiency, page 53

1.
 We note your response to prior comment one. On page 25 you disclose that you track paying players as a
performance metric. For more balanced disclosure, please consider disclosing the percentage of paying players in a given cohort that account for the cumulative revenues used to measure the payback period over your reported periods. For additional
context, with respect to your marketing efficiency, please consider disclosing the average lead time it takes new paying players to make their initial in-app purchases after their initial install of the game.

 Response to Comment No. 1:

The Company thanks the Staff for its comment and advises the Staff that it has added the following line item to the payback period table on
page 53 in consideration of the Staff’s comment:

2016

2017

2018

 New players contributing in payback period (%)

4.8

2.9

2.9

 In addition, the Company advises the Staff that, with respect to average lead time to initial purchase in the
payback period, the Company has experienced limited variance in average lead time to initial purchase from year to year during such period, with an average of 40 days over the three years from 2016 through 2018. Consequently, the Company does not
consider this a useful metric in measuring its marketing efficiency and, for competitive reasons, the Company does not wish to disclose the year-on-year information
specifically. However, the Company has revised the second paragraph under the table on page 53 as follows (new text in bold):

“Our payback period fluctuates based on our total cost of acquiring new players for a given period and our ability to subsequently
monetize those players. In recent years, we have experienced decreases in our payback period as our monetization of players has increased, resulting in a corresponding decrease in the percentage of players required in a given cohort to account
for cumulative revenues in the payback period. In addition, in the three-year period from 2016 through 2018, the average lead time to initial purchase in the payback period for a given cohort has remained relatively stable at approximately 40
days.”

 CONFIDENTIAL TREATMENT REQUESTED BY DOUBLEDOWN INTERACTIVE CO., LTD.

U.S. Securities and Exchange Commission

 June 18, 2020

 Page
 3

2.
 You disclose that your ability to effectively manage new player acquisition cost, or fees paid to marketing
partners for new installs, is a key competitive advantage to your business. Please also consider disclosing the year-over-year percentage change in such costs, relative to sales to highlight your ability to effectively manage new player acquisition
costs.

 Response to Comment No. 2:

The Company respectfully advises the Staff that it has considered the Staff’s recommendation to disclose the year-over-year percentage
change in the Company’s user acquisition costs, relative to sales. The Company has accordingly revised its explanation of sales and marketing expenses on page 63 to disclose the specific amounts related to user acquisition costs and its
percentage relative to sales as set out below (revised text in bold):

 “Sales and marketing expenses decreased by 10.3% from
$39.9 million in 2018 to $35.8 million in 2019, primarily due to a reduction in user acquisition advertising spend for DoubleDown Classic and Ellen’s Road to Riches in 2019, which was partially offset by an increase in
spend on DoubleDown Fort Knox. Total user acquisition advertising costs in 2018 was $31.6 million, representing 11.8% of revenue in 2018 and $28.5 million in 2019, representing 10.4% of revenue in
2019, and a decrease of 1.4 percentage points from 2018, which reflects the effectiveness of our player engagement strategies within the games to increase player purchases and management of total spend to ensure positive return on investment.
Total sales and marketing expenses as a percentage of revenue decreased by 1.8 percentage points from 14.9% in 2018 to 13.1% in 2019 [deletion].

Sales and marketing expenses for the three months ended March 31, 2020 increased $7.4 million over the comparative period, primarily
due to the increase in user acquisition costs [deletion]. Total user acquisition advertising costs increased $7.7 million to $13.0 million for the three months ended March 31, 2020
from $5.3 million for the three months ended March 31, 2019. The increase in investment to acquire new users was based on positive return on investment metric trends observed in the second half of 2019. Other
sales and marketing costs decreased 0.3 million from the three months ended March 31, 2020 due to change in personnel related expenses over the comparative period.”

Note 2. Significant Accounting Policies, page F-10

3.
 We note your response to prior comment four. Please illustrate how you derived deferred revenue of
$1.8 million as of December 31, 2019, using actual variables for your calculation in lieu of hypothetical data. Alternatively, tell us how you considered estimating the average price of the outstanding virtual currencies in your
players’ accounts to calculate deferred revenue and if you arrived at the same result.

 Response to Comment
No. 3:

 The Company acknowledges the Staff’s request for actual variables in lieu of the hypothetical data previously
provided in the response to prior Comment No. 4. The attached exhibit, which is provided supplementally and with respect to which confidential treatment is requested, includes the actual amounts for the calculation of inventory turns and how
the inventory turns is applied to actual sales to determine the deferred revenue liability at month-end.

 CONFIDENTIAL TREATMENT REQUESTED BY DOUBLEDOWN INTERACTIVE CO., LTD.

U.S. Securities and Exchange Commission

 June 18, 2020

 Page
 4

 As described in the Company’s prior responses, inventory turns represents the
consumption period over which virtual currency is consumed during gameplay. The management’s assumption is that game players generally do not purchase additional virtual currency until their existing virtual currency balances, regardless of
source (e.g, purchased currency, gifted currency through social media channels, daily free chips, etc.) have been substantially consumed. Revenue is recognized using a user-based revenue model with the period between purchases representing the
timing difference between virtual currency purchase and consumption. At December 31, 2019, this consumption period was [****] days.

The inventory turns in days is applied to daily sales to ratably recognize revenue over the period of time chips are consumed during game play.
This consumption period is relatively short ([****] days at December 31, 2019 as noted above). The exhibit provides a “waterfall” chart that is used to ratably distribute revenue over the consumption period and the amount deferred at
December 31, 2019.

 The Company further advises the Staff that it did not consider estimating the average price of outstanding virtual
currencies in player accounts to calculate deferred revenue because the Company is unable to isolate purchased chips. In other words, the Company is not able to distinguish between the consumption of purchased, bonused, free, or virtual currency
“wins” and “loses” that occur during gameplay.

 The Company’s approach instead is to determine the average
consumption period of all chips held by paying users. By applying the consumption period to actual purchases by day and ratably recognizing revenue, the Company believes this methodology most accurately recognizes revenue as its performance
obligation is satisfied. The Company also believes that its methodology for deferred revenue calculation is aligned with others in the industry. Based upon publicly available information, including filings with the Commission, the Company believes
that its peers also cannot or do not distinguish between the consumption of purchased or free virtual currency.

 We thank the
Staff for its review and consideration of the Company’s foregoing responses to the Staff’s comments. If the Staff needs any additional information or has any questions regarding the foregoing responses, please do not hesitate to contact
the undersigned at (310) 586-7773 or by email at jonesb@gtlaw.com.

Sincerely,

 /s/ Barbara A. Jones, Esq.

Barbara A. Jones, Esq.

cc:
 Office of International Corporate Finance, Securities and Exchange Commission

In Keuk Kim, Chief Executive Officer, DoubleDown Interactive Co., Ltd.

Joseph A. Sigrist, Chief Financial Officer, DoubleDown Interactive Co., Ltd.

Iksoo Kim, Esq., Greenberg Traurig, LLP

Attachment: Exhibit A

 CONFIDENTIAL TREATMENT REQUESTED BY DOUBLEDOWN INTERACTIVE CO., LTD.

Page 5

 EXHIBIT A

DoubleDown Interactive Co., Ltd.

 As of December 31, 2019

Data for the month ending December 31, 2019

[***]

[***]

[***]

[***]

[***]

[***]

[***]

[***]

[***]

[***]

[***]

[***]

[***]

[***]

[***]

[***]

 Deferred revenue calculation

[***]

[***]

[***]

[***]

[***]

[***]

 [***]

[***]

[***]

[***]

[***]

[***]

[***]

[***]

 [***]

[***]

 [***]

[***]

[***]

 [***]

[***]

[***]

[***]

 [***]

[***]

[***]

[***]

[***]

 [***]

[***]

[***]

[***]

[***]

[***]

 [***]

[***]

[***]

[***]

[***]

[***]

 [***]

[***]

[***]

[***]

[***]

 [***]

[***]

[***]

[***]

 [***]

[***]

[***]

Deferred Revenue

 [***]

[***]

$1,777,542.84

United States securities and exchange commission logo
June 12, 2020
In Keuk Kim
Chief Executive Officer
DoubleDown Interactive Co., Ltd.
13F, Gangnam Finance Center
152, Teheran-ro Gangnam-gu
Seoul 06236, Republic of Korea
Re:DoubleDown Interactive Co., Ltd.
Registration Statement on Form F-1
Filed June 2, 2020
File No. 333-238884
Dear Mr. Kim:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless otherwise
noted, where prior comments are referred to they refer to our letter dated May 27, 2020.
Registration Statement on Form F-1
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Our marketing efficiency, page 53
1.We note your response to prior comment one.  On page 25 you disclose that you track
paying players as a performance metric.  For more balanced disclosure, please consider
disclosing the percentage of paying players in a given cohort that account for the
cumulative revenues used to measure the payback period over your reported periods.  For
additional context, with respect to your marketing efficiency, please consider
disclosing the average lead time it takes new paying players to make their initial in-app
purchases after their initial install of the game.

 FirstName LastNameIn Keuk Kim
 Comapany NameDoubleDown Interactive Co., Ltd.
 June 12, 2020 Page 2
 FirstName LastName
In Keuk Kim
DoubleDown Interactive Co., Ltd.
June 12, 2020
Page 2
2.You disclose that your ability to effectively manage new player acquisition cost, or fees
paid to marketing partners for new installs, is a key competitive advantage to your
business.  Please also consider disclosing the year-over-year percentage change in such
costs, relative to sales to highlight your ability to effectively manage new player
acquisition costs.
Note 2. Significant Accounting Policies, page F-10
3.We note your response to prior comment four.  Please illustrate how you derived deferred
revenue of $1.8 million as of December 31, 2019, using actual variables for your
calculation in lieu of hypothetical data.  Alternatively, tell us how you considered
estimating the average price of the outstanding virtual currencies in your players' accounts
to calculate deferred revenue and if you arrived at the same result.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Kathryn Jacobson, Senior Staff Accountant, at (202) 551-3365 or Craig
Wilson, Senior Advisor, at (202) 551-3226 if you have questions regarding comments on the
financial statements and related matters. Please contact Jeff Kauten, Staff Attorney, at (202) 551-
3447 or Kathleen Krebs, Special Counsel, at (202) 551-3350 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Barbara A. Jones, Esq.

CORRESP
1
filename1.htm

Response Letter

 June 2, 2020

SUBMISSION VIA EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 100 F. Street,
N.E.

 Washington, D.C. 20549

Attn:
 Ms. Kathryn Jacobson

Mr. Craig Wilson

Mr. Jeff Kauten

Ms. Kathleen Krebs

Re:
 DoubleDown Interactive Co., Ltd.

Staff Comment Letter, dated May 27, 2020, in connection with

Amendment No. 2 to Draft Registration Statement on Form F-1, dated May 18, 2020

CIK No. 0001799567

 Ladies and
Gentlemen:

 This letter is submitted on behalf of DoubleDown Interactive Co., Ltd., a foreign private issuer organized under the laws of
the Republic of Korea (the “Company”), in response to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
with respect to the Company’s Amendment No. 2 to the draft Registration Statement on Form F-1 (as amended, the “Registration Statement”) confidentially submitted to the Commission on
May 18, 2020 (“Amendment No. 2”), as set forth in your letter dated May 27, 2020 addressed to Mr. In Keuk Kim, Chief Executive Officer of the Company (the “Comment Letter”).

The Company is concurrently submitting to the Commission, electronically via EDGAR, the Registration Statement on Form F-1, which includes changes that reflect responses to the Staff’s comments. In addition to addressing the Staff’s comments in the Comment Letter, the Company has revised the Registration Statement to
update certain other disclosures. As advised by the Staff in light of the COVID-19-related workplace issues, we are not at this time separately delivering to the
Commission for the Staff’s reference hard copies of Registration Statement and the exhibits filed therewith, but will of course do so in the future if and when the Staff considers appropriate.

Concurrently, the Company is also publicly filing, electronically via EDGAR, the draft Registration Statement on Form F-1, confidentially submitted to the Commission on January 21, 2020, Amendment No. 1 thereto as confidentially submitted on March 11, 2020, Amendment No. 2 thereto as confidentially submitted on
May 18, 2020, and the Company’s letters, dated March 11, 2020 and May 18, 2020, in response to the Staff’s comments. The Company currently intends to proceed with the offering in the near future, subject to market conditions
and other considerations, including compliance with the 15-day period set out in Section 6(e) of the Securities Act of 1933, as amended.

GREENBERG TRAURIG, LLP ∎ ATTORNEYS AT LAW ∎ WWW.GTLAW.COM

1840 Century Park East, Suite 1900 ∎ Los Angeles, California 90067-2121 ∎ Tel 310.586.7700 ∎ Fax 310.586.7800

 U.S. Securities and Exchange Commission

June 2, 2020

  Page
 2

 The headings and numbered paragraphs of this letter correspond to the same contained in the
Comment Letter, and to facilitate your review, the text of the Comment Letter has been reproduced herein, followed by the Company’s response to each comment. Unless otherwise indicated, page references in the descriptions of the Staff’s
comments refer to the Registration Statement.

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

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

Our Marketing Efficiency, page 51

1.
 We note your response to prior comment three. Please clarify what you mean by acquisition of players through
paid channels. Paid channel fees to your marketing partners would appear to be fees paid to those partners to acquire players and therefore it is not clear why an efficiency measure on the payback of those fees would include revenues from your
organically acquired player revenues.

 Response to Comment No. 1:

The Company advises the Staff that the acquisition of players through paid channels is the process by which the Company brings new users into
its games using advertising purchased by marketing partners. As set out in the Company’s prior response to Comment No. 3 in its letter of May 18, 2020, the Company believes it is appropriate to include revenue from organic
installs in its efficiency measure of its paid channels because the Company believes that the advertising showed by its marketing partners not only directly generates installs, but also influences players that organically install the app as they,
for example, search for the Company’s games in several apps stores or recommend that other players do so. This link between paid and organic installs is broadly understood in the mobile app industry and the correlation between the two has
been variously called “the K factor,” “the halo effect,” and “the incremental ratio.”

 Certain relationships and related
party transactions, page 103

2.
 Please add disclosure related to the acquisition of Double8 Games Co., Ltd. from DoubleU Games. Refer to Item
7.B of Form 20-F.

 Response to Comment No. 2:

The Company notes the Staff’s comment and has added the requested disclosure on page 106 as the third paragraph under “Our
relationship with DoubleU Games.”

 U.S. Securities and Exchange Commission

June 2, 2020

  Page
 3

 Note 2. Significant accounting policies

Basis of preparation and consolidation, page F-7

3.
 Please disclose the cause, nature and amounts of the line item adjustments to the Consolidated Financial
Statements for the periods presented on page F-3. Tell us your consideration of these adjustments as error corrections and the need for expanded disclosures. In this regard, we note that net income for 2019
declined by $3.5 million (approximately 10%) compared to the amount as reported in the previous amendment. Refer to ASC
250-10-50-7.

Response to Comment No. 3:

The Company respectfully advises the Staff that the adjustments made to the Consolidated Financial Statements for the periods presented on page
F-3 are not error corrections as defined under ASC 250-10-50-7. The Company determined
that the acquisition of Double8 Games was considered a transfer of a business under common control which represents a change in reporting entity and requires retrospective application to consolidated financial statements. In accordance with ASC 805-505-45-5, the Company retrospectively adjusted the financial statements and financial information presented for prior years to
furnish comparative information. Please refer to Note 1: Description of business – Acquisition of Double8 Games Co., Ltd. (“Double8 Games”).

Revenue recognition, page F-10

4.
 We note per your response to prior comment seven that the deferred revenue balance was $1.8 million at
December 31, 2019. Based on the actual amount of virtual currency outstanding, which includes fungible purchased and free virtual currency, please make clear how you calculated deferred revenue and how you considered free virtual currency in
determining the average price of all virtual currency outstanding in the paying players’ accounts at the end of the reporting period.

Please provide an example computation or additional analysis that demonstrates how combining the purchase time metric with other metric
analysis such as, average chip balance, daily average game play and daily average wagers reasonably supports your assumptions that the currency is consumed as game play between one purchase and the next, or five days.

Response to Comment No. 4:

The Company respectfully provides the Staff with more clarity on the calculation of deferred revenue. The Company uses a variety of metrics
including average chip balance, daily average gameplay, and daily average wagers to monitor player activity and to evaluate the appropriateness of our calculated reserve amounts on an ongoing basis. For clarity, not all metrics are used in the
actual calculation.

 As requested by the Staff, the Company sets out below a sample month-end calculation, using strictly hypothetical
amounts, for illustrative purposes only.

 Step 1: Calculate average daily consumption of chips: The Company identifies the average daily
chips wagered within the game and the average daily chips won during gameplay for all paying players during the month. Average daily consumption is calculated by subtracting average daily wagers from average daily chips won.

 Payers

Average daily
wagers

Average daily
chips won

Average
daily chip
consumption

 125,000

569,250,000

543,400,000

25,850,000

 Step 2: Calculate inventory turns: Inventory turns is defined as the average daily ending balance of all chips
held by paying users divided by the average daily consumption (calculated above) and is used to determine the days between purchases. Inventory turnover is calculated using both free and purchased virtual currency.

 Payers

Average daily
ending
balance

Average
daily chip
consumption

Inventory
turns (in
days)

 125,000

131,900,000

25,850,000

5.106

 Inventory turns represents the duration over which chips are consumed. To measure the deferred revenue
liability at month-end, calculated inventory turns is applied to the actual sales that occurred within the corresponding days at month-end.

 U.S. Securities and Exchange Commission

June 2, 2020

  Page
 4

 Contract assets, contract liabilities and other disclosures, page
F-11

5.
 We note your response to prior comment eight. We refer to the benefits of your loyalty program (“Diamond
Club”) as described on https://doubledowncasino1.zendesk.com/hc/en-us/articles/204901214. It appears that loyalty points earned for chip purchases provide a material right as loyalty members are entitled
to incremental benefits that do not reflect their stand-alone selling price. Additionally, such benefits (i.e., higher payout levels on the Daily Wheel, gifting options greater than the standard 3-gift limit,
and VIP vouchers that enable benefits of a chip sale) are only available to certain loyalty members based on their Club tier status attained through their cumulative purchases and are not otherwise available as a marketing offer or options for
entry-level loyalty members. Tell us how your accounting for loyalty points is consistent with the guidance in ASC 606-10-55-41
and 42. Please advise or revise.

 Response to Comment No. 5:

The Company respectfully advises the Staff that it has updated its webpage that refers to the loyalty program (“Diamond Club”). The
Company appreciates the Staff highlighting the language relating to the Daily Wheel, which had never been intended or designed to “ensure” higher payout as a player progresses through the loyalty tiers. Accordingly, the Company has updated
the relevant webpage by removing the phrase under the Daily Wheel description of “at each tier, values are increased, ensuring you receive bigger and better rewards over time!” and replacing it with the following language that reflects the
actual intent and operation of the Daily Wheel benefit: “As you achieve a higher level, the max wedge values are increased allowing the chance for you to receive better rewards over time!” The Daily Wheel bonus reward is not guaranteed and
only provides the Company’s players an opportunity to obtain free chips when they log on to the app.

 Supplementally, and solely for
the Staff’s information, we refer the Staff to the Company’s updated webpage at https://doubledowncasino1.zendesk.com/hc/en-us/articles/204901214-What-is-Diamond-Club-.

The Company respectfully sets out its evaluation of the loyalty program under the guidance in ASC 606, as requested by the Staff:

The Company evaluated the five steps of revenue recognition under ASC 606. The Company defines its contracts as virtual chip packages that
consist of virtual currency and loyalty points. These chip packages are uniform across all platform payment processors. The chip packages constitute the Company’s standard selling price. The Company, on a regular cadence, will offer chip sale
events whereby the amount of chips received is a greater multiple and the sale price remains constant. The explicit good that is promised is the virtual currency and the performance obligation is met as the player consumes the chips during gameplay.
Each sale transaction includes loyalty points. Loyalty points are not redeemable and are used as an engagement tool to show progress within the program. The Company evaluated whether the loyalty points give rise to an additional performance
obligation. To be a separate performance obligation, the loyalty points must provide a material right to the customer that the customer would not receive without entering into the contract (ASC 606-10-55-42).

To provide more context about how the Company’s app operates and functions, the Company respectfully sets out additional detail in support
of its conclusion:

 The Company’s gaming apps operate on a “free-to-play” model whereby players use virtual currency
(“chips”) to place wagers on casino-style games with the objective of winning additional virtual currency. As an engagement marketing tool and to motivate players to return to the app frequently, virtual chips are provided to the players
for free in several ways. As an example, upon first download and install, players are provided one million chips. To incentivize players to routinely return to the app, the Company offers daily free chips through a wide array of marketing
promotions. Utilizing various marketing and social channels, free chips are available for all classes of customers to redeem and return to the app for gameplay. Examples of free chip offers include cell phone push notifications, emails, and Facebook
page posts. There is no limit to the redemption of these marketing offers, which total approximately five million free chips daily. Ninety-five percent of all players play for free via these chips provided daily. Players who chose to continue their
gameplay, beyond these free chip opportunities, may purchase additional chips.

 All paying customers are automatically enrolled in the
Diamond Club loyalty program. Loyalty points are earned with chip purchases and the points accumulate to allow for advancement into a higher tier with the loyalty program. Loyalty points are not redeemable and are used only to track progress through
the loyalty tiers. The loyalty program offers the following benefits: the opportunity for a greater payout on the Daily Wheel, the increasing ability to redeem daily gifts of free chips from friends, and VIP vouchers on future purchases.

The Daily Wheel provides all players, both paying and nonpaying, a chance opportunity to receive free chips once per day. The top
opportunity value of free chips on the Daily Wheel, as well as the probability weighted average amount of free chips, increases as a paying player progresses through the loyalty tiers. The probability weighted average payout of a Daily Wheel spin in
the highest loyalty tier is less than the 5 million free chips readily available to all players without purchase or achievement of any loyalty tier through the marketing offers noted above. ASC 606-10-55-42 states that when an entity grants a
customer the option to acquire additional goods or services, that option is a separate performance obligation if it provides a material right that the customer would not receive without entering into the contract (e.g., a discount that exceeds the
range of discounts typically given for those goods or services to that class of customer in that region or market). Because 5 million free chips are readily available to all players without purchase or achievement of any loyalty tier, the Company
concluded that the benefits conveyed through higher potential payouts of the Daily Wheel spin are not incremental to the range of discounts the Company normally offers and, therefore, do not constitute a material right.

The Company’s gifting program is a marketing offer to encourage its players to bring their Facebook friends to its gaming apps. If they
choose, all players, both paying players and non-paying players, can send a daily free ch

United States securities and exchange commission logo
May 27, 2020
In Keuk Kim
Chief Executive Officer
DoubleDown Interactive Co., Ltd.
13F, Gangnam Finance Center
152, Teheran-ro Gangnam-gu
Seoul 06236, Republic of Korea
Re:DoubleDown Interactive Co., Ltd.
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted May 18, 2020
CIK No. 0001799567
Dear Mr. Kim:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.  Unless otherwise noted, where prior comments are referred to they refer to our letter
dated March 27, 2020.
Amendment No. 2 to Draft Registration Statement on Form F-1
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Our Marketing Efficiency, page 51
1.We note your response to prior comment three.  Please clarify what you mean by
acquisition of players through paid channels.  Paid channel fees to your marketing
partners would appear to be fees paid to those partners to acquire players and therefore it
is not clear why an efficiency measure on the payback of those fees would
include revenues from your organically acquired player revenues.

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Certain relationships and related party transactions, page 103
2.Please add disclosure related to the acquisition of Double8 Games Co., Ltd. from
DoubleU Games.  Refer to Item 7.B of Form 20-F.
Note 2. Significant accounting policies
Basis of preparation and consolidation, page F-7
3.Please disclose the cause, nature and amounts of the line item adjustments to
the Consolidated Financial Statements for the periods presented on page F-3.  Tell us your
consideration of these adjustments as error corrections and the need for expanded
disclosures. In this regard, we note that net income for 2019 declined by $3.5 million
(approximately 10%) compared to the amount as reported in  the previous amendment.
Refer to ASC 250-10-50-7.
Revenue recognition, page F-10
4.We note per your response to prior comment seven that the deferred revenue balance was
$1.8 million at December 31, 2019.  Based on the actual amount of virtual currency
outstanding, which includes fungible purchased and free virtual currency, please make
clear how you calculated deferred revenue and how you considered free virtual
currency in determining the average price of all virtual currency outstanding in the paying
players' accounts at the end of the reporting period.

Please provide an example computation or additional analysis that demonstrates how
combining the purchase time metric with other metric analysis such as, average chip
balance, daily average game play and daily average wagers reasonably supports your
assumptions that the currency is consumed as game play between one purchase and the
next, or five days.
Contract assets, contract liabilities and other disclosures, page F-11
5.We note your response to prior comment eight.  We refer to the benefits of your loyalty
program ("Diamond Club") as described
on https://doubledowncasino1.zendesk.com/hc/en-us/articles/204901214.  It appears that
loyalty points earned for chip purchases provide a material right as loyalty members are
entitled to incremental benefits that do not reflect their stand-alone selling price.
Additionally, such benefits (i.e., higher payout levels on the Daily Wheel, gifting options
greater than the standard 3-gift limit, and VIP vouchers that enable benefits of a chip sale)
are only available to certain loyalty members based on their Club tier status attained
through their cumulative purchases and are not otherwise available as a marketing offer or
options for entry-level loyalty members.  Tell us how your accounting for loyalty points is
consistent with the guidance in ASC 606-10-55-41 and 42.  Please advise or revise.

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May 27, 2020
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Subsequent events, page F-13
6.As disclosed, on May 15, 2020, DoubleU Games (“DUG”) exercised the call option to
purchase the 2.5% Non-convertible Bonds with warrants issued to STIC and exercised the
warrants by surrendering the 2.5% Non-convertible Bonds into 306,539 common shares at
the exercise price of KRW 293,600 (US$240.03 at May 1, 2020 with initial conversion
price of $254,00).  Concurrently, STIC agreed to convert the 2.5% 7-year convertible
bonds into 715,258 newly-issued common shares at the conversion price of KRW 293,00
(US$240.03 at May 1, 2020) no later than June 5, 2020.  Please disclose the financial
impact of these transactions and clarify whether the down-round and contingent beneficial
conversion  provisions have been triggered.  We note the change in the conversion price.
See ASC 855-10-50-2.
            You may contact Kathryn Jacobson, Senior Staff Accountant, at (202) 551-3365 or Craig
Wilson, Senior Advisor, at (202) 551-3226 if you have questions regarding comments on the
financial statements and related matters. Please contact Jeff Kauten, Staff Attorney, at (202) 551-
3447 or Kathleen Krebs, Special Counsel, at (202) 551-3350 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Barbara A. Jones, Esq.

March 27, 2020
In Keuk Kim
Chief Executive Officer
DoubleDown Interactive Co., Ltd.
13F, Gangnam Finance Center
152, Teheran-ro Gangnam-gu
Seoul 06236, Republic of Korea
Re:DoubleDown Interactive Co., Ltd.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted March 12, 2020
CIK No. 0001799567
Dear Mr. Kim:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.  Unless otherwise noted, where prior comments are referred to they refer to our letter
dated February 18, 2020.
Amendment No. 1 to Draft Registration Statement on Form F-1
Risk Factors
Risks related to our relationship with DoubleU Games, page 28
1.We note that you have removed the risk factor related to your status as a controlled
company.  Please include this risk factor in your filing as your status as a controlled
company presents risks that are separate and apart from your status as a foreign private
issuer.

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In Keuk Kim
DoubleDown Interactive Co., Ltd.
March 27, 2020
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations
Our business, page 44
2.We note in your filing you have a declining number of players year over year.
Additionally, you derive a significant portion of your revenues from a small number of
high-paying players.  Please discuss your vulnerability to a near-term severe impact
arising from the disruption of the economy by the COVID-19 pandemic which could
affect the discretionary spending behavior of such players and thus, your revenues.  In
addition, disclose other material known or reasonably likely effects of and the types of
risks presented by COVID-19 on your financial position, results of operations, accounting
judgments and estimates and timeliness of your financial reporting.  Refer to ASC 275-10-
50-16 and CF Disclosure Guidance Topic No. 9: Coronavirus (COVID-19)
at https://www.sec.gov/corpfin/coronavirus-covid-19.
Our marketing efficiency, page 46
3.Please revise to clarify your new computation for average payback period that replaces
CPI.  We note it measures time by days for 3rd party costs to be paid back, but it uses
"cumulative revenue generated by all of the players in a given install period." If your
use of  "all players" includes organic and paid channel revenues to measure payback
periods, tell us why it is appropriate to include organic revenues unrelated to the
marketing partners fees.
Other key performance indicators and non-GAAP metrics and trends, page 47
4.We note your responses to comments 11 and 12.  Please balance your disclosure to
indicate how growth in your subscription revenue, if at all, contributed towards your total
revenue growth, ARPDAU, and average monthly revenue per user.

Furthermore, you disclose your mobile penetration represents the percentage of revenue
sourced from the Google, Apple and Amazon platforms but do not include Facebook. Tell
us why and disclose other platform revenue sources, amounts and percentages. Tell us and
disclose what comprises the balance of your revenue penetration for the periods, both
online or mobile. Also disclose whether the high paying players are predominantly mobile
or online players. To the degree there are any material trends among the individual
platform sources, mobile versus online  or high-paying players please revise your MD&A
accordingly. We refer you to Item 5.D of Form 20-F.

5.We note your response to prior comment 5.  You disclose that monetization of active
players is a key factor affecting your financial performance.  You indicate that this
monetization comes from players’ purchases of in-game virtual chips, which is how you
generate substantially all of your revenue.  You further disclose that the proportion of
revenue from high-paying players (those who spend more than $500 per month) has been
gradually rising in recent years.  Please tell us whether you use any metrics to monitor

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March 27, 2020
Page 3
your revenue concentration and the impact of high-paying customers on your financial
performance, such as the percentage of revenue derived from high-paying players, number
of high-paying players as a percentage of paying players or average revenue per high-
paying player.  If so, please provide a discussion of these metrics or other related metrics
and any material trends.  We refer you to Item 5.D of Form 20-F.
Critical accounting policies and estimates
Recent accounting guidance adopted, page 61
6.Please disclose to state, if true, whether the conversion feature of the 2.5% convertible
bonds and the May 2017 warrants contain a down round provision.  If so, please further
disclose as follows:
•how you concluded whether the conversion feature or the warrants met the scope
exception in ASC 815-40 for  classification in stockholders' equity;
•whether either instrument contains terms or features other than the down round
feature that would cause liability classification on the basis of  the guidance in Topic
480 or Subtopic 815-40;
•how you evaluated the 2.5% convertible bonds under accounting guidance for debt
with conversion and other options under ASC 470-20;
•how a down round feature in the warrants  will impact the calculation of basic EPS
when triggered.

Note 2: Significant accounting policies
Revenue Recognition, page F-10
7.We note your response to prior comment 21.  You recognize virtual chip or currency
revenues when control transfers upon consumption of this currency.  Please explain and
disclose further the basis for your determination that player purchase of virtual currency
determines consumption of the currency and thereby affects revenue recognition.  In this
regard, address the assumptions used in estimating virtual currency consumption based on
your analysis of customers' historical play behavior, purchase behavior, and the amount of
virtual currency outstanding.

You disclose on page 60 you estimate the outstanding purchased virtual currency at period
end because you are unable to distinguish between the consumption of purchased versus
free currency.  Tell us and disclose the assumptions used to estimate this amount, how you
considered free currency/chips obtained during game play and through player actions on
social media outside of gameplay, as well as forfeitures, and explain the impact of any
uncertainties.  Revise to disclose this in your financial statement revenue recognition
note.

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Contract assets, Contract liabilities and other disclosures, page F-11
8.We note your response to comments 21 and 23. Elsewhere in your filing, you referred to
your loyalty program subject to a third party registration. Describe the terms of the loyalty
program and the nature of incentives and rewards that players may receive.  Disclose
whether participation in the loyalty program  provides a material right that the player
would not receive otherwise, thereby giving rise to a separate performance obligation to
which a portion of the transaction price must be allocated.  Refer to ASC 606-10-55-41
& 42.
Principal-agent considerations, page F-11
9.We note in your response to comment 22 that the platform providers have no rights to
control how the company defines its pricing. You disclose on page 77 that your platform
providers have the "ability to make unilateral changes to their platforms, their terms of
service, the amounts of or method by which  players obtain content and make payments,
how they are paid, and any other aspect of their platforms and services." Please clarify the
disclosure regarding your platform providers' inability to change your pricing. To the
extent your arrangements with Apple, Facebook and Google allow them to offer
incentives, discounts or otherwise change the price defined by you for virtual chips, tell us
whether you know the actual amount paid by your players and how that impacts the
amount you record as revenue.

Regarding your  arrangement with Facebook, please provide us your analysis as to
whether you have control or visibility over the issuance of extra chips  (up to 9 million
chips each year) in the Daily Wheel spin of each player logged onto Facebook when such
player's Facebook friends also play DoubleDown Casino. Clarify whether the invitations
to friends through the Facebook platform results in greater fees retained by Facebook.
Refer to the benefits of connecting through Facebook in DoubleDown Casino
at https://doubledowncasino1.zendesk.com/hc/en-us/articles/201395160-Benefits-of-
connecting-through-Facebook-in-DoubleDown-Casino.
Note 4: Debt, page F-16
10.We note your response to comments 24 and 26 and your revised disclosures.  With respect
to the 2.5% convertible bonds and the May 2017 warrants, please clarify and state if true
whether "certain adjustments for anti-dilution protection" constitute a down round
provision or whether they may be deemed standard anti-dilution protection..

Further clarify how your assessment of such provisions  could be affected by the
probability (or remote likelihood) of price adjustment(s) or by such adjustments being
under your control.  Refer to your basis in the accounting literature.

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In Keuk Kim
DoubleDown Interactive Co., Ltd.
March 27, 2020
Page 5
            You may contact Kathryn Jacobson, Senior Staff Accountant, at (202) 551-3365 or Craig
Wilson, Senior Advisor, at (202) 551-3226 if you have questions regarding comments on the
financial statements and related matters.  Please contact Jeff Kauten, Staff Attorney, at (202)
551-3447 or Kathleen Krebs, Special Counsel, at (202) 551-3350 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Barbara A. Jones, Esq.

February 18, 2020
In Keuk Kim
Chief Executive Officer
DoubleDown Interactive Co., Ltd.
13F, Gangnam Finance Center
152, Teheran-ro Gangnam-gu
Seoul 06236, Republic of Korea
Re:DoubleDown Interactive Co., Ltd.
Draft Registration Statement on Form F-1
Submitted January 21, 2020
CIK No. 0001799567
Dear Mr. Kim:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1
Cover Page
1.Please identify the entity that will control the company and disclose the percentage of
voting power that will be held by that entity after the consummation of the offering.
Our Company, page 1
2.You disclose on page 2 the average time per day spent by an average U.S. adult on a
smartphone in 2019. Please disclose the amount of time the average U.S. adult spent on
mobile gaming.

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3.Please clarify why you believe your market opportunity includes the global casual gaming
market when it appears that the games you offer are within the social casino segment of
casual gaming.  Disclose that you currently generate most of your revenue from the
United States.
Risk Factors
Risks related to our business and industry, page 12
4.Please add a risk factor that addresses the general decline in your average monthly active
users and your average daily active users.
We rely on a small percentage of our players…, page 12
5.Please provide additional context regarding your statement that you derive nearly all of
your revenue from a small percentage of your players by disclosing the amount or
percentage of your revenue derived from these players and the percentage of your paying
players from which this revenue is derived.
Our DoubleDown Casino game has generated substantially all of our revenue…, page 13
6.Please disclose the percentage of your revenue generated by your DoubleDown Casino
game.
Risks related to our relationship with DoubleU Games, page 28
7.Please add risk factor disclosure addressing the following:
•Whether you have any agreements governing conflicts of interest between the
company and DoubleU Games.
•Whether a controlling shareholder owes fiduciary duties to a company and its
minority shareholders under Korean law.  In this regard, discuss how any fiduciary
duties owed by a controlling shareholder may differ under Korean law from U.S.
corporate law and how that might affect the ability of minority shareholders or the
company to protect their respective interests.
Our marketing efficiency, page 45
8.For each period presented, please provide comparative data on your average cost per
installation, or CPI, in the table that contains your payback period. In this regard, we note
that your payback period fluctuates based on your CPI for a given period and that you
monitor CPI across marketing channels in real-time.

In addition, disclose the components of installation costs and address significant changes
in cost behavior to the extent that they have caused fluctuations in each  reported payback
period.  Refer to the  Commission Guidance on Management’s Discussion and Analysis of
Financial Condition and Results of Operations (Release 33-10751) at
https://www.sec.gov/rules/interp/2020/33-10751.pdf

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February 18, 2020
Page 3

9.Please disclose your basis for calculating payback period and further define install period
(if other than each year presented).
10.Additionally, please make clear that your measurement of marketing efficiency is based
solely  on Doubledown Casino, which, as you indicated on page 5, provides substantially
all of your revenue to date. Qualify your disclosure to address how the resultant payback
periods from long-standing games can be different from new releases based on their
respective average installation costs.
Other key performance indiators and non-GAAP metrics and trends, page 46
11.We note the negative trends in your Average MAU and Average DAU for consecutive
quarters. Considering that these metrics are indicators of the potential number of paying
players and engagement of your player base, please disclose how such declines have
impacted  current period revenues, whether they are expected to continue,  and whether
declining trends could foretell declining future revenues from paying players. Further
balance your disclosure by addressing the implications of  favorable ARPDAU trends
resulting from declining average DAU.
Revenue and key performance indicators, page 50
12.On page 12, you indicate that you derive nearly all your revenue from the sale of virtual
chips to a small percentage of paying players and that the proportion of revenue from
high-paying players (those who spend more than $500 per month) has been gradually
rising in recent years.  To enable your investors to better understand the extent of your
revenue concentration, please disclose the proportion of high paying players in relation to
the total number of paying players overall for each period presented.
Other income and other expenses, page 53
13.Revise to disclose the basis for and the nature of the gains on foreign currency transaction
and the remeasurements of intercompany items.
Liquidity and capital resources, page 55
14.Please disclose the principal amount of convertible bonds and bonds with warrants that are
outstanding. File the debt and warrant agreements as exhibits.
Certain relationships and related party transactions
Our relationships with DoubleU Games, page 91
15.Please file the loan agreements with DoubleU Games Co., Ltd. as exhibits.
16.Please disclose the amounts paid to DoubleU Games Co., Ltd. under the DoubleU Games
License Agreement for the years ended December 31, 2018 and 2019.  Refer to Item 7.B
of Form 20-F.

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Joint investment agreement, page 91
17.Please clarify whether the joint investment agreement between DoubleU Games and STIC
Special Situation Private Placement Joint Stock Company will continue unchanged after
the offering. Provide risk factor disclosure of how this agreement will influence the
company's corporate governance and operations. Disclose in the prospectus summary that
the agreement gives the parties the right to nominate a majority of the company's board of
directors. Identify the directors nominated by each party in your management disclosure.
File the agreement as an exhibit.
18.Please disclose the number and percentage of shares issuable pursuant to the conversion
of the convertible bonds and exercise of the warrants held by STIC Special Situation
Private Placement Joint Stock Company.
Consolidated financial statements
Consolidated statement of net income and comprehensive income, page F-3
19.You disclose on the face of the income statement that depreciation and amortization is
excluded from cost of revenue. To avoid placing undue emphasis on “cash flow,”
depreciation and amortization should not be positioned in the income statement in a
manner which results in reporting a figure for income (i.e., Gross Profit) before
depreciation. Please revise to  include applicable depreciation and amortization in cost of
revenue. In the alternative, please remove the line item captioned "Gross Profit." Please
revise other presentations of Gross Profit throughout the filing. Refer to SAB Topic 11B.
Consolidated statement of changes in shareholder's equity, page F-5
20.We note the material gain of $12 million on foreign currency translation, net of tax within
the column "Accumulated other comprehensive income/(loss)" for the year ended
December 31, 2018.  Please revise to include the disclosures related to the foreign
currency activity required by ASC 830-45-18 and 20 and 830-30-50-1.  Tell us how you
considered addressing the gain within Management's Discussion and Analysis.
Note 2: Significant accounting policies
Revenue Recognition, page F-10
21.Please tell us and clarify what the estimated period of time is that you recognize virtual
currency revenue over the reported periods.  In addition, please explain and clarify what
you mean that for "most apps, revenue is recognized using a user-based revenue model."
Principal-agent considerations, page F-11
22.Notwithstanding that various third-party platforms collect proceeds from your customers
and remit an amount to you after deducting a platform fee, you record revenues on a gross
basis.  As stated hereunder, you have determined that you have control over the content
and functionality of games prior to access by the end-user and therefore, are the principal

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in the arrangement.  Addressing the terms of your arrangements with the third-party
platform providers, tell us your assessment as to how your conclusion about control aligns
with the principal indicators in ASC 606-10-55-39.
Contract assets, Contract liabilities and other disclosures, page F-12
23.Please disclose the nature of performance obligations specified in your non-cancellable
contracts governing customer purchases of virtual currency, as well as your recently
launched subscription model (page 48). Further describe when and how the respective
performance obligations are satisfied. Refer to ASC 606-10-50-12.
New accounting guidance not yet adopted, page F-13
24.Tell us how you evaluated the impact of adopting Part I (Accounting for Certain Financial
Instruments with Down Round Features) of  ASU 2017-11.  In this regard, we note your
disclosure on page F-16 that the BW warrants  have a down round feature.  Additionally,
the conversion price for the CB bonds, similar to the warrant exercise price, is subject to
an adjustment based on both the magnitude and size and price of new equity offerings.
Segment information, page F-13
25.Please revise to disclose entity-wide information and information on geographic areas and
products and services of your operating segment pursuant to ASC 280-10-50-38 through
41.
Note 4: Term loans, convertible bonds, and bonds with warrants
Convertible bonds and bonds with warrants, page F-16
26.Please disclose the numbers of shares into which the CB bonds are convertible and  the
BW warrants are exercisable based on their respective formulas.  Describe how they can
be affected by  the magnitude of both the size and price of new equity financing.  Refer to
ASC 505-10-50-7.

Additionally, please explain what you mean by a "low probability of occurrence" and why
it is a factor for ascribing no value to a down round feature.  Refer to your basis in the
accounting literature.
Bond Warrants , page F-19
27.Revise to disclose the rights and privileges of the bond warrants pursuant to ASC 505-10-
50-3.
Note 6: Shareholder's equity
Common Stock, page F-19
28.You disclosed that your common stock has no preemptive rights.  However, on page 95,
you made reference to preemptive rights of all stockholders who are listed on your

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stockholders register as of the relevant record date.  Please clarify the inconsistencies and
disclose such preemptive rights, if any. Additionally, disclose the shareholders' privilege
to receive a distribution of free shares (when applicable) as further indicated on page
95. Please confirm to us that your Note 6. disclosures comply with ASC 505-10-50-3.
General
29.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.
30.Please disclose the source of the statement in your prospectus that DoubleDown Casino
has been in the top 20 grossing mobile games on Apple App Store since 2015.
            You may contact Kathryn Jacobson, Senior Staff Accountant, at (202) 551-3365 or Craig
Wilson, Senior Advisor, at (202) 551-3226 if you have questions regarding comments on the
financial statements and related matters.  Please contact Jeff Kauten, Staff Attorney, at (202)
551-3447 or Kathleen Krebs, Special Counsel, at (202) 551-3350 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Barbara A. Jones, Esq.