<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                             April 16, 2025

Ryuichi Sasaki
Chief Executive Officer
CTW Cayman
29F, 1 Chome-9-10, ARK Hills Sengokuyama Mori Tower
Roppongi, Minato City, Tokyo 106-0032, Japan

       Re: CTW Cayman
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted March 31, 2025
           CIK 0002047148
Dear Ryuichi Sasaki:

     We have reviewed your amended draft registration statement and have the
following
comments.

       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 a comment applies 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 this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our March 4, 2025 letter.

Amendment No. 1 of Draft Registration Statement on Form F-1
Risk Factors
We are an "emerging growth company" within the meaning of the Securities
Act..., page 43

1.     We note your revised disclosure in response to prior comment 10. Please
further
       revise and refer to "our" financial statements instead of "your"
financial statements.
Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 56

2.     We note your revised disclcosure in response to prior comment 12 where
you
       disclose the nature of each of your competitors included in the
competitive global
 April 16, 2025
Page 2

       ranking of H5 games platforms (by gross billings) in 2023. With respect
to the table
       on page 76, disclose the identity of each referenced competitor.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Operating Metrics, page 59

3.     Please revise, both here and on page 13, to explain how you calculate
monthly active
       users (MAUs) and paying monthly active users (PMAUs). Clarify whether
the
       amounts provided for fiscal 2024 and 2023 represent the MAU and PMAU for
a
       particular month or an average of the MAUs for each month throughout the
year.
4.     The amounts in the examples provided in your response to prior comment
13 do not
       agree to the gross in-game purchases or PMAU and MAU information
provided in the
       chart on page 59. Please explain and revise as necessary.
5.     You state in your response to prior comment 14 that management believes
MAU
       information provides investors with sufficient granularity to evaluate
"individual
       game performance." Please tell us how MAU provides information on
individual
       games when this metric relates to all users on your platform regardless
of the game. In
       addition, explain how disclosing DAUs would create a misleading
impression that
       you place significant emphasis on individual game performance rather
than overall
       platform performance. In this regard, you state that your key focus is
on paying users
       and their spending behavior, which directly impacts revenue and net
income.
       However, it is unclear why user engagement on your platform would not
impact the
       number of paying users and potentially increase the amount spent in the
games on
       your platform. Therefore, please explain further how you determined user
engagement
       is not relevant to your business.
6.     We note your revised disclosures in response to prior comment 15. Please
explain
       further how Day 1, Day 7 and Day 30 retention rates are calculated for
an entire year.
       In this regard, clarify whether retention rates for fiscal 2024 and 2023
represent the
       rates for a specific point in time during the year or an average
throughout the year.
       Explain how you determine the number of active users on Day 0. For
example, tell us
       whether Day 0 includes all users that start a game on that particular
day and confirm
       whether you follow those same users throughout their time spent in the
game (i.e.
       through Day 1, Day 7 and Day 30). In addition, your reference to Day 0
refers to the
       day the player first starts "the game." Clarify whether your retention
calculations
       include all games played on your platform. Lastly, revise your
disclosures as
       necessary to address these points.
7.     We note your revised disclosures in response to comment 16, including
the definition
       of return on average spend (ROAS) on page 13. Please provide us with the
       calculations that support the ROAS percentages disclosed on page 59.
Clarify what is
       meant by "average in-game purchase amount" as referenced on page 13 and
how it is
       determined. To the extent this differs from gross in-game purchase
amounts
       referenced throughout the filing, explain why.
 April 16, 2025
Page 3
Notes to Combined Financial Statements
Note 2 - Summary of Significant Accounting Policies
Revenue recognition, page F-12

8.     We note the revised disclosures where you indicate that the Group
distributes games
       on behalf of the game developers through its platform, enabling end
users' access to
       the game for an initial period of three years from the date it is
launched. Please tell us
       what typically happens after this initial period ends. Clarify whether a
new contract is
       entered into, and if so, disclose the typical terms of such
arrangements. To the extent
       you no longer provide access to the games at the end of this initial
term, revise the
       forepart of the filing to include a discussion of the related risks.
Revise to disclose
       whether any games are nearing the end of the initial period and are at
risk of no longer
       being available to end users, and discuss the potential impact to your
operations.

        Please contact Melissa Kindelan at 202-551-3564 or Kathleen Collins at
202-551-
3499 if you have questions regarding comments on the financial statements and
related
matters. Please contact Mariam Mansaray at 202-551-6356 or Larry Spirgel at
202-551-3815
with any other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
cc:   Richard J. Chang, Esq.
</TEXT>
</DOCUMENT>
