SecProbe.io

November 8, 2018
Ann Hand
Chief Executive Officer
Super League Gaming, Inc.
2906 Colorado Ave.
Santa Monica, CA 90404
Re:Super League Gaming, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted October 26, 2018
CIK No. 0001621672
Dear Ms. Hand:
            We have reviewed your amended draft registration statement 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 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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amended Draft Registration Statement Submitted on October 26, 2018
Risk Factors, page 9
1.We note your response to our prior comment 15.  In an appropriate place in your
prospectus please disclose the fact that you do not currently have formal agreements
with Supercell and Epic Games relating to Clash Royale and Fortnite events.  In addition
please add a risk factor discussing risks attendant to you not having such licenses.

 FirstName LastNameAnn Hand
 Comapany NameSuper League Gaming, Inc.
 November 8, 2018 Page 2
 FirstName LastName
Ann Hand
Super League Gaming, Inc.
November 8, 2018
Page 2
Our Business, page 54
2.We note your response to our prior comment 8.  Please revise on page 58 to clarify how
an increase of $869 million resulting in a valuation of $137.9 billion represents a year
over year increase of 13.3%.  It appears that an $869 million increase would be an
increase of less than 1%.
3.We note your response to our prior comment 8.  For the non-subscriber data shown in the
first two bar charts on page 59, please disclose the time period for which audience data are
calculated.  For example, if unique monthly viewers is shown please so state.  We also
note from several sources that Twitch reports unique monthly viewers of approximately
140 million viewers.  Explain why you show a higher number.  Finally, discuss
the reasons why the size of the esports audience is smaller than the Youtube Gaming and
Twitch audiences so that investors can better understand the differences.
4.We note your response to our prior comment 10.  Please disclose that, as stated in your
response, you are currently unable to accurately calculate the estimated increase in
revenue associated with the monthly average users and/or players of new game titles as
shown on page 61.
            You may contact Heather Clark at 202-551-3624 or Jean Yu at 202-551-3305 if you
have questions regarding comments on the financial statements and related matters. Please
contact John Dana Brown at 202-551-3859 or Anne Parker, Assistant Director, at 202-551-3611
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure