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                             August 5, 2021

       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 July 20, 2021
                                                            File No. 333-258032

       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.

       Registration Statement on Form F-1

       Notes to Condensed Consolidated Financial Statements (Unaudited)
       Note 10. Commitments and Contingencies, page F-39

   1.                                                   Regarding the Benson
case (cited on page 97 and unnamed hereunder), we note that no
                                                        amount has been
recorded in connection with the lawsuit. However, on page 98, you
                                                        stated that "if we were
to settle the Benson lawsuit at this time ... such settlement would
                                                        likely be for a
significant monetary amount and our operating results and financial
                                                        condition could be
materially adversely affected." In this regard, you indicated that
                                                        similar class actions
have finalized settlements in amounts ranging up to $155 million
                                                        (page 97). You further
disclosed on page 98 that your insurer will not cover such expenses
                                                        or any losses that
could arise for any settlement amount or damages award in this
 In Keuk Kim
FirstName  LastNameIn
DoubleDown   InteractiveKeuk
                         Co., Kim
                              Ltd.
Comapany
August     NameDoubleDown Interactive Co., Ltd.
       5, 2021
August
Page 2 5, 2021 Page 2
FirstName LastName
         particular case. In view of a court order for the parties to settle,
material legal settlements
         in precedent cases, absent any insurance coverage nor indemnification
from your co-
         defendant, please tell us why you did not accrue a loss in your
financial statements. It
         appears that a loss is probable and reasonably estimable based on your
statement on page
         98 that "prior to the resolution of the Benson case, we may be
required, or otherwise deem
         it advisable, to record a material financial reserve in respect of a
potential adverse
         outcome." Refer to ASC 450-20-25-2 through 25-5.
2.       We understand that Hanover Insurance Co. had filed a declaratory
judgment action
         alleging that its insurance policy does not cover the claims made by
NEXRF Corp. in its
         patent infringement suit. On page 98, you stated that due to the early
nature of this case, it
         is not possible to assess whether this case may be material to your
business.
         Notwithstanding, in light of the reasonable possibility that a loss
may have been
         incurred, please disclose the amount of the settlement demand made by
NEXRF Corp.
         Refer to ASC 450-20-50-3 through 50-4.
General, page F-41

3.       Please include a footnote on subsequent events disclosing your
evaluation of the effects of
         all subsequent events through the date the financial statements were
issued. Refer to ASC
         855-10-25-1.
4.       Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications.
        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.
 In Keuk Kim
DoubleDown Interactive Co., Ltd.
August 5, 2021
Page 3

       You may contact Kathryn Jacobson, Senior Staff Accountant, at (202)
551-3365 or
Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have
questions regarding
comments on the financial statements and related matters. Please contact Jeff
Kauten, Staff
Attorney, at (202) 551-3447 or Larry Spirgel, Office Chief, at (202) 551-3815
with any other
questions.



                                                          Sincerely,
FirstName LastNameIn Keuk Kim
                                                          Division of
Corporation Finance
Comapany NameDoubleDown Interactive Co., Ltd.
                                                          Office of Technology
August 5, 2021 Page 3
cc:       Barbara A. Jones, Esq.
FirstName LastName