December 3, 2024

Alexander Karavaev
Chief Financial Officer
GDEV Inc.
55 Griva Digeni
3101, Limassol
Cyprus

        Re: GDEV Inc.
            Form 20-F for the Fiscal Year Ended December 31, 2023
            Response dated November 6, 2024
            File No. 001-40758
Dear Alexander Karavaev:

        We have reviewed your November 6, 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 October
23, 2024 letter.

Form 20-F for the Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
Note 4. Accounting judgments, estimates and assumptions
Revenue Recognition , page F-28

1.     Please address the following as it relates to your response to prior
comment 1:
           You state that no revenue is recognized on the sale of virtual
currency until such
           currency is converted, and the converted virtual currency follows
the same
           revenue recognition pattern as the consumable or durable goods.
Revise your
           policy disclosures to indicate as such.
           You state that the balance of unconverted virtual currency was
$485,000 and
           $780,000 at December 31, 2023 and 2022, respectively. Tell us how
this relates to
           the $98 million and $129 million, respectively of bookings from
acquisition of
 December 3, 2024
Page 2

           virtual currency not recognized as revenue as provided in the table
to your
           response, as well as to the $350 million and $392 million in
deferred revenue at
           December 31, 2023 and 2022, respectively.
             Clarify whether the balance of not yet converted virtual currency
is included in
           deferred revenue at period-end.
             If virtual currency is not recognized in revenue until such
currency is converted,
           explain to us why management splits the currency not yet converted
at period end
           between consumable and durable virtual goods.
             Provide us with a breakdown of revenue from in-game purchases
between point-
           in-time (i.e. consumable goods) and over-time (i.e. durable goods)
for each period
           presented.
Note 5. Segment Reporting, page F-38

2.     We note your proposed revised disclosures in response to prior comment
3. Please
       consider revising the "Total" column for Segment Management EBITDA to
include
       "N/A" instead of a dash. In this regard, the dash may give the
appearance that the total
       is $0 for this line item.
       Please contact Dave Edgar at 202-551-3459 or Kathleen Collins at
202-551-3499 if
you have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:   J. David Stewart