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                           February 16, 2021

       Xueji Wang
       Chief Executive Officer
       Tuya Inc.
       10/F, Building A, Huace Center
       Xihu District, Hangzhou City
       Zhejiang, 310012
       People   s Republic of China

                                                        Re: Tuya Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted February
9, 2021
                                                            CIK No. 0001829118

       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 otherwise noted, where prior comments are referred to
they refer to our letter
       dated February 2, 2021.

       Draft Registration Statement on Form F-1

       Prospectus Summary
       Overview, page 1

   1.                                                   We note your response
to prior comment 1. Please disclose that none of these named
                                                        customers represents a
material portion of your revenue.
 Xueji Wang
FirstName
Tuya Inc. LastNameXueji Wang
Comapany16,
February  NameTuya
            2021   Inc.
February
Page 2 16, 2021 Page 2
FirstName LastName
Notes to the Consolidated Financial Statements
Note 2. Principle Accounting Policies
(s) Advances from Customers, page F-22

2.       We note your response to prior comment 15. Please explain to us why
amounts are
         recorded in the advances from customers rather than in deferred
revenue and revise to
         disclose the difference between these line items. Also, we note your
revised disclosures
         indicate that advances related to "SaaS and others" are reclassified
into deferred revenue
         and recognized as revenue over time. However, the deferred revenue
disclosures on page
         on F-32 indicate these amounts relate to the cloud-based connectivity
and basic IoT
         services. Please tell us and clarify your disclosures to explain how
you account for
         amounts paid in advance for SaaS and other related services, including
whether and when
         they are recorded as deferred revenue.
        You may contact Melissa Kindelan, Staff Accountant, at (202) 551-3564
or Christine
Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions
regarding comments on
the financial statements and related matters. Please contact Jeff Kauten, Staff
Attorney, at (202)
551-3447 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology
cc:      James C. Lin, Esq.