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December 13, 2023

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:

Aliya Ishmukhamedova

Jan Woo

Ryan Rohn

Stephen Krikorian

Re:

Joint Stock Company Kaspi.kz

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

Confidentially submitted on November 9, 2023

CIK No. 0001985487

Ladies and Gentlemen:

This letter sets forth the responses of Joint Stock Company Kaspi.kz (the “Company”) to the comments contained in your letter, dated December 11, 2023, relating to Amendment No. 2 to the Draft Registration Statement on Form F-1, confidentially submitted by the Company on November 9, 2023 (the “Amendment No. 2”). The comments of the staff of the U.S. Securities and Exchange Commission (the “Staff”) are set forth in bold italicized text below, and the Company’s responses are set forth in plain text immediately following each comment.

The Company is submitting confidentially, via EDGAR, Amendment No. 3 to the Draft Registration Statement on Form F-1 (“Amendment No. 3”).

Capitalized terms used but not defined herein have the meanings assigned to them in Amendment No. 3.

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

Cover Page

1.	Please revise the cover page to clearly state that the ADSs being sold in the offering by the selling shareholders are a portion of the existing Regulation S GDRs that will have been redesignated as ADSs. Additionally, clarify what currency the ADSs will trade in on each exchange.

In response to the Staff’s comment, the Company has revised the cover page and other disclosures to state that the ADSs to be sold in the offering will represent a portion of the Regulation S GDRs that will have been redesignated as ADSs and to state the currency that the Company’s securities will be quoted in on each exchange that such securities are traded on.