September 16, 2019 Yahui Zhou Chief Executive Officer Opera Limited Gjerdrums vei 19, 0484 Oslo, Norway Re: Opera Limited Registration Statement on Form F-3 Filed September 10, 2019 File No. 333-233691 Dear Mr. Zhou: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Edwin Kim, Staff Attorney, at (202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any questions. Sincerely, Division of Corporation Finance Office of Information Technologies and Services cc: Ben James, Esq.