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                            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.
 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,
FirstName LastNameIn Keuk Kim
                                                             Division of
Corporation Finance
Comapany NameDoubleDown Interactive Co., Ltd.
                                                             Office of
Technology
June 12, 2020 Page 2
cc:       Barbara A. Jones, Esq.
FirstName LastName