September 17, 2024

Yao (Jessie) Liu
Chief Financial Officer
Tuya Inc.
10/F, Building A, Huace Center
Xihu District, Hangzhou City
Zhejiang, 310012
People's Republic of China

        Re: Tuya Inc.
            Form 20-F for the Fiscal Year Ended December 31, 2022
            Response dated January 19, 2024
            File No. 001-40210
Dear Yao (Jessie) Liu:

       We have reviewed your January 19, 2024 response to our comment letter
and have the
following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

        After reviewing your response to this letter, we may have additional
comments. Unless we
note otherwise, any references to prior comments are to comments in our
December 15,
2023 letter.

Form 20-F for the Fiscal Year Ended December 31, 2022
General

1.     Based on the information provided in response to prior comment 1, and in
previous
       correspondence, we do not necessarily agree with your view that
short-term deposits
       with maturities of one year or less may be treated as    cash items
for purposes of section
       3(a)(1)(C) of the Investment Company Act of 1940 (the    Investment
Company Act   ).
       Please confirm your understanding of the same.
2.     We note the company   s representations that the company has
significantly reduced, and
       will continue to significantly reduce, its consolidated holdings in both
long-term and
       short-term time deposits. On the basis of these representations, and
apart from comment
       1 above, we have no further questions or comments with respect to the
company   s time
 September 17, 2024
Page 2

       deposit holdings.
3.     In response to prior comment 7 in our letter dated October 16, 2023, you
provided a draft
       risk factor disclosing risks related to the company potentially
operating as an    investment
       company    under the Investment Company Act. In future filings, please
make the
       following changes:
           To the extent the company continues to hold substantial positions in
time deposits
           (including short-term deposits) on a consolidated basis, please
revise your risk factor
           disclosure to reflect comment number 1 above.
           To the extent the company continues to hold substantial positions in
time deposits
           (including short-term deposits) on a consolidated basis, please
ensure that your risk
           factor notes the same and that such time deposits may deemed to be
 investment
           securities    within the meaning of the Investment Company Act.

       Please contact Melissa Kindelan at 202-551-3564 or Christine Dietz at
202-551-3408 if
you have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:   Xiaolang Chai, Capital Market Director