August 6, 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. 2 to Draft Registration Statement on Form F-1
           Submitted July 23, 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
July 6, 2018 letter.

Draft Registration Statement on Form F-1

Risk Factors, page 15

1.     Please provide risk factor disclosure explaining that as a result of
your election to delay
       the adoption of new or revised accounting standards that have different
effective dates for
       public and private companies until those standards apply to private
companies, your
       financial statements may not be comparable to companies that comply with
public
       company effective dates.
 Michael Wang
FirstName LastNameMichael Wang
CooTek (Cayman) Inc.
Comapany2018
August 6, NameCooTek (Cayman) Inc.
August 6, 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
Effectiveness of monetization, page 78

2.       Please revise to explain the reasons for the quarterly fluctuations in
the percentage
         changes in the effective price per impression and the number of
average daily impressions
         delivered on global portfolio products.
Quantitative and Qualitative Disclosures about Market Risk, page 95

3.       You state that the majority of your expenses and a certain percentage
of your revenues
         are denominated in RMB. To the extent that the conversion of U.S.
dollars into RMB has
         materially impacted your historical financial results, please include
a discussion of any
         known trends that you reasonably expect will have a material favorable
or unfavorable
         impact on your financial results. Refer to Item 5.A and 5.D of Form
20-F.

Unaudited Condensed Financial Statements as of June 30, 2018
Unaudited Condensed Consolidated Statements of Operations, page F-43

4.       We note your disclosure that pro forma EPS is not presented because
the effect of the
         conversion of the outstanding convertible redeemable preferred stock
would be anti-
         dilutive. Considering you present pro forma information on the face of
the historical
         condensed balance sheet to reflect the conversion of these shares into
ordinary shares,
         please also include pro forma EPS on the face of the historical
statement of operations for
         the most recent period. Your footnotes should also disclose pro forma
EPS for the most
         recent annual period and reflect the calculation of pro forma EPS for
both periods. Pro
         forma EPS information for the most recent fiscal year should also be
presented in the
         summary consolidated financial data and selected consolidated
financial data tables.
General

5.       On page 77, you include North Korea among countries that comprise East
Asia, one of the
         regions with active users of your products. We also are aware of
publicly available
         industry reports that mobile devices produced by several of the
business partners you
         identify on your website are available in Iran, North Korea, Sudan
and/or Syria. Iran,
         North Korea, Sudan and Syria are countries that are designated by the
U.S. Department of
         State as state sponsors of terrorism and are subject to U.S. economic
sanctions and/or
         export controls. You do not include disclosure in the draft
registration statement about
         contacts with the referenced countries. Please describe to us the
nature and extent of any
         past, current and anticipated contacts with Iran, North Korea, Sudan
and Syria, including
         with their governments, whether through business partners, customers
or other direct or
         indirect arrangements.
         You may contact Rebekah Lindsey, Staff Accountant, at 202-551-3303 or
Kathleen
 Michael Wang
CooTek (Cayman) Inc.
August 6, 2018
Page 3

Collins 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.



                                                           Sincerely,
FirstName LastNameMichael Wang
                                                           Division of
Corporation Finance
Comapany NameCooTek (Cayman) Inc.
                                                           Office of
Information Technologies
August 6, 2018 Page 3                                      and Services
FirstName LastName