July 10, 2018

Michael Wang
Chief Executive Officer
CooTek (Cayman) Inc.
2nd Floor, Building 7, No. 2007 Hongmei Road, Xuhui District
Shanghai, 201103
People's Republic of China

       Re: CooTek (Cayman) Inc.
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted June 21, 2018
           CIK No. 0001734262

Dear Mr. Wang:

      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 we note otherwise, our references to prior comments are to
comments in our
June 6, 2018 letter.

Amendment No. 1 to Draft Registration Statement filed June 21, 2018

Prospectus Summary
Our Business, page 1

1.     We note from your revised disclosure in response to prior comment 2 that
the number of
       times TouchPal Smart Input launched in the second half of 2017 was
generally consistent
       with that in March 2018. Please clarify what you mean by generally
consistent and
       supplementally provide us with the number of launch times for each
period presented.
 Michael Wang
FirstName LastNameMichael Wang
CooTek (Cayman) Inc.
Comapany NameCooTek (Cayman) Inc.
July 10, 2018
July 10, 2018 Page 2
Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Factors Affecting Our Results of Operations, page 75

2.       We note your response to prior comment 8. Please clarify the countries
that comprise the
         regions of East Asia, South Asia and Southeast Asia.
3.       We note your response to prior comment 9. Please tell us the
percentage of performance-
         based advertising revenue generated from arrangements that were based
on the number of
         clicks for each period presented. Also, while you state that
management considers the
         number of impressions delivered and the effective price per impression
present more
         comprehensive information of your results of operations and are more
important
         indicators of your performance-based revenue, please clarify whether
management
         reviews any other metrics such as number of clicks when analyzing
performance.
4.       Please refer to prior comment 10. If your key metrics are impacted by
seasonality or other
         events, discussion of those factors is useful to an understanding of
your business and the
         quarterly results disclosed on page 85. Please revise to provide the
percentage change in
         the number of impressions and the effective price per impression for
the relevant quarters
         for which you have data available.
5.       Please refer to our prior comment 12. It is unclear how you concluded
that disclosure of
         the number of DAUs and MAUs for your TouchPal Phoneboook application
for each
         quarter would not provide material information to investors. While we
understand that
         this revenue stream is declining as a percentage of total revenues,
considering it comprises
         45% and 31% of your advertising revenues for fiscal 2016 and 2017,
respectively, please
         provide the requested disclosure or provide additional information as
to why this
         disclosure is not meaningful.
Description of American Depositary Shares
Governing Law and Dispute Resolution, page 166

6.       We note your statement that the waiver of jury trial provision does
not apply to "any
         claims against us arising under the United States federal securities
laws." Please clarify
         whether the waiver of the right to a jury trial applies to claims
under the U.S. federal
         securities laws against the depositary or other parties to the
agreement.
Consolidated Financial Statements
Note 19. Subsequent Events, page F-36

7.       You state that you granted restricted shares in March 2018, however,
you disclose the
         terms for options grants. To the extent you granted restricted shares,
please disclose the
         terms for such awards. In addition, please provide us with a breakdown
of all equity
         awards granted during fiscal 2017 and to date in fiscal 2018, and
include the fair value of
         the underlying common stock used to value such awards. To the extent
there were any
         significant fluctuations in the fair values from period-to-period,
please describe for us the
 Michael Wang
CooTek (Cayman) Inc.
July 10, 2018
Page 3
         factors that contributed to these fluctuations, including any
intervening events within the
         company or changes in your valuation assumptions or methodology.
        You may contact Rebekah Lindsey, Staff Accountant, at 202-551-3303 or
Kathleen
Collins, Accounting Branch Chief, at 202-551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Jeff Kauten,
Staff Attorney, at
202-551-3447 or Barbara C. Jacobs, Assistant Director, at 202-551-3735 with any
other
questions.


FirstName LastNameMichael Wang
                                                               Division of
Corporation Finance
Comapany NameCooTek (Cayman) Inc.
                                                               Office of
Information Technologies
July 10, 2018 Page 3                                           and Services
FirstName LastName