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                              August 14, 2023

       David Li
       Chief Executive Officer
       JOYY Inc.
       30 Pasir Panjang Road #15-31A Mapletree Business City
       Singapore 117440

                                                        Re: JOYY Inc.
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            File No. 001-35729

       Dear David Li:

              We have limited our review of your filing to the submission
and/or disclosures as
       required by Item 16I of Form 20-F 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 20-F for the Fiscal Year Ended December 31, 2022

       Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 172

   1.                                                   We note your statement
that you reviewed your register of members and public EDGAR
                                                        filings made by your
shareholders in connection with your required submission under
                                                        paragraph (a). Please
supplementally describe any additional materials that were reviewed
                                                        and tell us whether you
relied upon any legal opinions or third party certifications such as
                                                        affidavits as the basis
for your submission. In your response, please provide a similarly
                                                        detailed discussion of
the materials reviewed and legal opinions or third party
                                                        certifications relied
upon in connection with the required disclosures under paragraphs
                                                        (b)(2) and (3).
   2.                                                   In order to clarify the
scope of your review, please supplementally describe the steps you
                                                        have taken to confirm
that none of the members of your board or the boards of your
                                                        consolidated foreign
operating entities are officials of the Chinese Communist Party. For
                                                        instance, please tell
us how the board members    current or prior memberships on, or
                                                        affiliations with,
committees of the Chinese Communist Party factored into your
                                                        determination. In
addition, please tell us whether you have relied upon third party
 David Li
JOYY Inc.
August 14, 2023
Page 2
      certifications such as affidavits as the basis for your disclosure.
3.    We note that your disclosures pursuant to Items 16I(b)(2) and (b)(3) are
provided for
         JOYY Inc.    or    JOYY Inc., its subsidiaries or the variable
interest entities.    We also note
      that your list of subsidiaries in Exhibit 8.1 appears to indicate that
you have subsidiaries in
      Hong Kong and countries outside China that are not included in your VIEs.
Please note
      that Item 16I(b) requires that you provide disclosures for yourself and
your consolidated
      foreign operating entities, including variable interest entities or
similar structures.
          With respect to (b)(2), please supplementally clarify the
jurisdictions in which your
           consolidated foreign operating entities are organized or
incorporated and provide the
           percentage of your shares or the shares of your consolidated
operating entities owned
           by governmental entities in each foreign jurisdiction in which you
have consolidated
           operating entities in your supplemental response.
          With respect to (b)(3), please provide the required information for
you and all of your
           consolidated foreign operating entities in your supplemental
response.

        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 Tyler Howes at 202-551-3370 or Andrew Mew at 202-551-3377
with any
questions.



                                                              Sincerely,
FirstName LastNameDavid Li
                                                              Division of
Corporation Finance
Comapany NameJOYY Inc.
                                                              Disclosure Review
Program
August 14, 2023 Page 2
cc:       Haiping Li, Esq.
FirstName LastName