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United States securities and exchange commission logo
December 30, 2020
Bing Jin
Chief Financial Officer
JOYY Inc.
Building B-1
North Block of Wanda Plaza, No. 79 Wanbo Er Road
Nancun Town, Panyu District
Guangzhou 511442
The People s Republic of China
Re: JOYY Inc.
Form 20-F for the
Year Ended December 31, 2019
Filed April 27,
2020
Form 6-K filed
November 17, 2020
File No. 001-35729
Dear Mr. Jin:
We have limited our review of your filings to the financial
statements and related
disclosures and have the following 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 6-K filed November 17, 2020
Exhibit 99.2
Third Quarter 2020 Operational Highlights, page 1
1. We note that during
both the second and third quarters of 2020, the total number of paying
users of YY decreased
compared to the corresponding periods of 2019. Your disclosures
indicate this decline
was due to COVID-19 impacts. Please revise future filings and
supplementally explain
in greater detail how COVID-19 negatively impacted the number
of paying users of YY
while the average mobile MAUs for YY global live streaming
services increased over
the same periods.
Bing Jin
JOYY Inc.
December 30, 2020
Page 2
Form 20-F for the Year Ended December 31, 2019
Item 5. Operating and Financial Review and Prospects
Operating Results, page 93
2. Please revise your future filings beginning with your Form 20-F for
the period ended
December 31, 2020 to provide updated disclosures about the specific
impacts of COVID-
19 on your operations, liquidity and capital resources. Please refer
to CF Disclosure
Guidance: Topic 9A, which is available on the Commission's website.
In closing, 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.
You may contact Lisa Haynes Etheredge, Staff Accountant at (202)
551-3424 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 with any questions.
FirstName LastNameBing Jin Sincerely,
Comapany NameJOYY Inc.
Division of
Corporation Finance
December 30, 2020 Page 2 Office of Technology
FirstName LastName