SEC Comment Letter 0000000000-23-006897 to SharpLink Gaming Ltd. (CIK 0001025561)
SharpLink Gaming Ltd. (CIK 0001025561)
Date: June 28, 2023 · CIK: 0001025561 · Accession: 0000000000-23-006897
AI Filing Summary & Sentiment
File numbers found in text: 000-28950
Letter
United States securities and exchange commission logo June 28, 2023 Robert DeLucia Chief Financial Officer SharpLink Gaming Ltd. 333 Washington Avenue North, Suite 104 Minneapolis, Minnesota 55401 Re:SharpLink Gaming Ltd. Form 10-K for the Fiscal Year Ended December 31, 2022 File No. 000-28950 Dear Robert DeLucia: We have limited our review of your filing 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 10-K for the Fiscal Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations., page 1.Please emphasize your going concern status in the forefront of your MD&A and in Liquidity and Capital Resources discussion. General 2.We note that on December 22, 2022 you acquired SportsHub. It appears that SportsHub assets were over 200% of your assets prior to the acquisition. Tell us how you considered Rules 8-04 and 8-05 of Regulation S-X in regard to filing the financial statements and pro forma information for the SportsHub acquisition. 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.
FirstName LastNameRobert DeLucia Comapany NameSharpLink Gaming Ltd. June 28, 2023 Page 2 FirstName LastName Robert DeLucia SharpLink Gaming Ltd. June 28, 2023 Page 2 You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Robert Littlepage, Accounting Branch Chief at 202-551-3361 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
June 28, 2023
Robert DeLucia
Chief Financial Officer
SharpLink Gaming Ltd.
333 Washington Avenue North, Suite 104
Minneapolis, Minnesota 55401
Re:SharpLink Gaming Ltd.
Form 10-K for the Fiscal Year Ended December 31, 2022
File No. 000-28950
Dear Robert DeLucia:
We have limited our review of your filing 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 10-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations., page
40
1.Please emphasize your going concern status in the forefront of your MD&A and
in Liquidity and Capital Resources discussion.
General
2.We note that on December 22, 2022 you acquired SportsHub. It appears that
SportsHub assets were over 200% of your assets prior to the acquisition. Tell us how you
considered Rules 8-04 and 8-05 of Regulation S-X in regard to filing the financial
statements and pro forma information for the SportsHub acquisition.
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.
FirstName LastNameRobert DeLucia
Comapany NameSharpLink Gaming Ltd.
June 28, 2023 Page 2
FirstName LastName
Robert DeLucia
SharpLink Gaming Ltd.
June 28, 2023
Page 2
You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371 or Robert
Littlepage, Accounting Branch Chief at 202-551-3361 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology