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                              December 11, 2023

       Mikheil Lomtadze
       Chief Executive Officer
       Joint Stock Co Kaspi.kz
       154A Nauryzbay Batyr Street
       Almaty, 050013, Kazakhstan

                                                        Re: Joint Stock Co
Kaspi.kz
                                                            Amendment No. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted November
9, 2023
                                                            CIK No. 0001985487

       Dear Mikheil Lomtadze:

            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.

       Amendment No. 2 to Draft Registration Statement on Form F-1 submitted
November 9, 2023

       Cover page

   1.                                                   Please revise the cover
page to clearly state that the ADSs being sold in the offering by the
                                                        selling shareholders
are a portion of the existing Regulation S GDRs that will have been
                                                        redesignated as ADSs.
Additionally, clarify what currency the ADSs will trade in on each
                                                        exchange.
       Risk Factors
       The ADSs will trade on more than one market and this may result in
increased volatility..., page
       65

   2.                                                   Please confirm the
accuracy of the last sentence of this risk factor and whether the current
                                                        shares will remain in
their current markets. Revise the risk factor to clarify that ADSs will
                                                        also trade on KASE
 Mikheil Lomtadze
Joint Stock Co Kaspi.kz
December 11, 2023
Page 2

       Please contact Ryan Rohn at 202-551-3739 or Stephen Krikorian at
202-551-3488 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Jan Woo at 202-551-3453 with
any other
questions.



                                                        Sincerely,
FirstName LastNameMikheil Lomtadze
                                                        Division of Corporation
Finance
Comapany NameJoint Stock Co Kaspi.kz
                                                        Office of Technology
December 11, 2023 Page 2
cc:       Nicholas P. Pellicani
FirstName LastName