Sea Limited SC 13G Sea / BAILLIE GIFFORD & CO ownership change

SCHEDULE 13G

CUSIP No.

81141R100

Names of Reporting Persons

BAILLIE GIFFORD & CO

Check the appropriate box if a member of a Group (see instructions)

(a)

(b)

Sec Use Only

Citizenship or Place of Organization

UNITED KINGDOM

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 29,574,967.00
6	Shared Voting Power 0.00
7	Sole Dispositive Power 40,954,549.00
8	Shared Dispositive Power 0.00

Aggregate Amount Beneficially Owned by Each Reporting Person

40,954,549.00

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

Checkbox not checked

Percent of class represented by amount in row (9)

7.8 %

Type of Reporting Person (See Instructions)

SCHEDULE 13G

Item 1.

(a)

Name of issuer:

Sea Ltd

(b)

Address of issuer's principal executive offices:

C/O 1 FUSIONOPOLIS PLACE, # 17-10, GALAXIS, SINGAPORE, SINGAPORE, 138522.

Item 2.

(a)

Name of person filing:

Baillie Gifford & Co

(b)

Address or principal business office or, if none, residence:

Calton Square 1 Greenside Row Edinburgh EH1 3AN Scotland UK

(c)

Citizenship:

Scotland

(d)

Title of class of securities:

Class A Ordinary Share

(e)

CUSIP No.:

81141R100

Item 3.

If this statement is filed pursuant to §§ 240.13d-1(b) or 240.13d-2(b) or (c), check whether the person filing is a:

(a)

Broker or dealer registered under section 15 of the Act (15 U.S.C. 78o);

(b)

Bank as defined in section 3(a)(6) of the Act (15 U.S.C. 78c);

(c)

Insurance company as defined in section 3(a)(19) of the Act (15 U.S.C. 78c);

(d)

Investment company registered under section 8 of the Investment Company Act of 1940 (15 U.S.C. 80a-8);

(e)

An investment adviser in accordance with § 240.13d-1(b)(1)(ii)(E);

(f)

An employee benefit plan or endowment fund in accordance with § 240.13d-1(b)(1)(ii)(F);

(g)

A parent holding company or control person in accordance with § 240.13d-1(b)(1)(ii)(G);

(h)

A savings associations as defined in Section 3(b) of the Federal Deposit Insurance Act (12 U.S.C. 1813);

(i)

A church plan that is excluded from the definition of an investment company under section 3(c)(14) of the Investment Company Act of 1940 (15 U.S.C. 80a-3);

(j)

A non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J). If filing as a non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J),
please specify the type of institution:

(k)

Group, in accordance with Rule 240.13d-1(b)(1)(ii)(K).

Investment Adviser

Item 4.

Ownership

(a)

Amount beneficially owned:

40,954,549 (These are held as 40,954,549 American Depositary Shares (ADS) with one ordinary share representing one ADS.)

(b)

Percent of class:

7.77 %

(c)

Number of shares as to which the person has:

(i) Sole power to vote or to direct the vote:

29,574,967 (These are held as 29,574,967 American Depositary Shares (ADS) with one ordinary share representing one ADS.)

(ii) Shared power to vote or to direct the vote:

(iii) Sole power to dispose or to direct the disposition of:

40,954,549 (These are held as 40,954,549 American Depositary Shares (ADS) with one ordinary share representing one ADS.)

(iv) Shared power to dispose or to direct the disposition of:

Item 5.

Ownership of 5 Percent or Less of a Class.

Item 6.

Ownership of more than 5 Percent on Behalf of Another Person.

If any other person is known to have the right to receive or the power to direct the receipt of dividends from, or the proceeds from the sale of, such securities, a statement to that effect should be included in response to this item and, if such interest relates to more than 5 percent of the class, such person should be identified. A listing of the shareholders of an investment company registered under the Investment Company Act of 1940 or the beneficiaries of employee benefit plan, pension fund or endowment fund is not required.

Securities reported on this Schedule 13G as being beneficially owned by Baillie Gifford & Co. are held by Baillie Gifford & Co. and/or one or more of its investment adviser subsidiaries, which may include Baillie Gifford Overseas Limited, on behalf of investment advisory clients, which may include investment companies registered under the Investment Company Act, employee benefit plans, pension funds or other institutional clients.

Item 7.

Identification and Classification of the Subsidiary Which Acquired the Security Being Reported on by the Parent Holding Company or Control Person.

Not Applicable

Item 8.

Identification and Classification of Members of the Group.

Not Applicable

Item 9.

Notice of Dissolution of Group.

Not Applicable

Item 10.

Certifications:

By signing below I certify that, to the best of my knowledge and belief, the securities referred to above were acquired and are held in the ordinary course of business and were not acquired and are not held for the purpose of or with the effect of changing or influencing the control of the issuer of the securities and were not acquired and are not held in connection with or as a participant in any transaction having that purpose or effect, other than activities solely in connection with a nomination under ? 240.14a-11. By signing below I certify that, to the best of my knowledge and belief, the foreign regulatory scheme applicable to Investment Adviser is substantially comparable to the regulatory scheme applicable to the functionally equivalent U.S. institution(s). I also undertake to furnish to the Commission staff, upon request, information that would otherwise be disclosed in a Schedule 13D.

SIGNATURE

After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete and correct.

BAILLIE GIFFORD & CO

Signature:	Grant Meikle
Name/Title:	Threshold and Transaction Reporting Manager
Date:	02/12/2025

Sea Limited (SE) SC 13GSea / BAILLIE GIFFORD & CO ownership change