DOUBLEDOWN INTERACTIVE CO., LTD.
13F, Gangnam Finance Center
152, Teheran-ro Gangnam-gu
Seoul 06236, Republic of Korea
June 25, 2020
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C. 20549
Attention: Ms. Kathryn Jacobson
Mr. Craig Wilson
Mr. Jeff Kauten
Ms. Kathleen Krebs
| Re: | DoubleDown Interactive Co., Ltd. |
Registration Statement on Form F-1 (File No. 333-238884)
Registration Statement on Form 8-A (File No. 001-39349)
Registration Statement on Form F-6 (File No. 333-239022)
Request for Acceleration of Effectiveness
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), DoubleDown Interactive Co., Ltd., a foreign private issuer organized under the laws of the Republic of Korea (the “Company”), hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form F-1 (File No. 333-238884), and the corresponding Registration Statement on Form 8-A (File No. 001-39349), so that such Registration Statements shall become effective at 12:00 p.m. (EDT) on June 30, 2020, or as soon thereafter as practicable. Once the Registration Statements have been declared effective, please orally confirm that event with our counsel, Greenberg Traurig, LLP., by calling Barbara A. Jones, Esq. at 310.586.7773.
The Company also joins a request that is concurrently being filed by Citibank, N.A. requesting that the Company’s Registration Statement on Form F-6 (File No. 333-239022) be declared effective simultaneously with the Registration Statement on Form F-1. The Company intends to commence trading in the Company’s ADSs on or about July 1, 2020 on the Nasdaq Global Select Market.
The Company acknowledges the following:
| • | should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or the staff, acting pursuant to delegated authority in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
| Very truly yours, | ||||||
| DOUBLEDOWN INTERACTIVE CO., LTD. | ||||||
| By: | /s/ In Keuk Kim | |||||
| Name: In Keuk Kim | ||||||
| Title: Chief Executive Officer | ||||||
cc: Joseph A. Sigrist, Chief Financial Officer, DoubleDown Interactive Co., Ltd.
Barbara Jones, Esq., Greenberg Traurig, LLP
Iksoo Kim, Esq., Greenberg Traurig, LLP