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                               November 8, 2022

       Andrey Fadeev
       Chief Executive Officer
       Nexters Inc.
       55, Griva Digeni
       3101, Limassol
       Cyprus

                                                        Re: Nexters Inc.
                                                            Post-Effective
Amendment No. 5 to Form F-1
                                                            Filed October 18,
2022
                                                            File No. 333-259707

       Dear Andrey Fadeev:

              We have limited our review of your post-effective amendment to
those issues we have
       addressed in our 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.
Unless we
       note otherwise, our references to prior comments are to comments in our
September 27, 2022
       letter.

       Post-Effective Amendment No. 5 to Registration Statement on Form F-1

       Cover Page

   1.                                                   Please clarify the
disclosure you provided in response to prior comment 1. You appear to
                                                        indicate that the
selling securityholders will not sell their shares and warrants pursuant to
                                                        the prospectus so long
as the trading on Nasdaq remains suspended. Please clarify if that
                                                        is the case. If not,
please indicate the fixed price at which the selling securityholders will
                                                        sell their shares and
warrants until trading resume on Nasdaq. In this regard, it is not clear
                                                        that the disclosed fair
value of the shares and warrants is the fixed price at which the
                                                        securityholders will
sell their securities or whether the offering price will fluctuate based
 Andrey Fadeev
Nexters Inc.
November 8, 2022
Page 2
      on estimated fair values using the methodology set forth in Note 22 of
the interim
      financial statements.
2.    We note your disclosure in response to prior comment 2, including using
the average price
      paid by the Sponsor for the ordinary shares it is offering to calculate
the Sponsor   s
      potential profit. Please only disclose the potential profit for shares
that were purchased by
      the Sponsor at prices below the last market price rather than netting
potential sales at a
      profit with potential sales at a loss. For example, specifically disclose
the potential profit
      the Sponsor could earn on the sale of its 6,750,000 founders shares
purchased for $25,000,
      or approximately $0.00325 per share. In addition, as requested in prior
comment 2,
      disclose on the prospectus cover page the price that the Sponsor acquired
its ordinary
      shares and warrants, and the price that the SPAC's public securityholders
acquired their
      ordinary shares and warrants. Also disclose that Mr. Tavrin, who has sole
dispositive
      power over company's shares held by the Sponsor, has caused the Sponsor
to offer all
      of its securities in this offering, consisting of 11,750,000 shares and
6,125,000 warrants.
       As appropriate, revise the disclosure in the risk factor on page 46.
        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 Kathleen Krebs, Special Counsel, at 202-551-3350 or
Joshua Shainess,
Legal Branch Chief, at 202-551-7951 with any other questions.



                                                             Sincerely,
FirstName LastNameAndrey Fadeev
                                                             Division of
Corporation Finance
Comapany NameNexters Inc.
                                                             Office of
Technology
November 8, 2022 Page 2
cc:       J. David Stewart, Esq.
FirstName LastName