August 21, 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.
           Registration Statement on Form F-1
           Filed August 16, 2018
           File No. 333-226867

Dear Mr. Wang:

       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.

Registration Statement on Form F-1 filed on August 16, 2018

Cover Page

1.     Given Mr. Zhang's ownership of all of CooTek's Class B ordinary shares
with each Class
       B ordinary share entitled to 25 votes, please clarify whether the
company will be a
       "controlled company" under the definition of the New York Stock Exchange
after the
       offering and provide disclosure in this section as well as in the
prospectus summary and
       risk factors sections, to the extent appropriate.
 Michael Wang
CooTek (Cayman) Inc.
August 21, 2018
Page 2
Management, page 143

2.    We note that you have appointed Mr. Haibing Wu and Ms. Jue Yao as
independent
      directors upon effectiveness of the registration statement. Please file
their written
      consents as required by Securities Act Rule 438.
        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 Rebekah Lindsey, Staff Accountant, at 202-551-3303 or
Kathleen 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
                                                            Office of
Information Technologies
Comapany NameCooTek (Cayman) Inc.
                                                            and Services
August 21, 2018 Page 2
cc:       Julie Gao, Esq.
FirstName LastName