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SEC Comment Letter for Super League Enterprise, Inc. (SLE) (CIK 0001621672) (SLE) — Feb 5, 2019

Super League Enterprise, Inc. (SLE) (CIK 0001621672)
Date: Feb. 5, 2019 · CIK: 0001621672 · Accession: 0000000000-19-001050

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 333-229144

Referenced dates: November 11, 2018

Date
February 5, 2019
Author
Not clearly detected
Form
UPLOAD
Company
Super League Enterprise, Inc. (SLE) (CIK 0001621672)

Letter

February 5, 2019 Ann Hand Chief Executive Officer Super League Gaming, Inc. 2906 Colorado Ave. Santa Monica, CA 90404 Re:Super League Gaming, Inc. Registration Statement on Form S-1 Filed January 4, 2019 File No. 333-229144 Dear Ms. Hand: We have reviewed your 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 amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Form S-1 filed January 4, 2019 Our Business, page 54 1.We note your response to prior comment 3 from our letter dated November 11, 2018. Please expand to clarify that the chart titled “Twitch & YouTube Gaming have a larger audience than many entertainment platforms” reports annual audience figures as of the end of 2016 for each platform. Executive Compensation, page 85 2.Please revise to include executive compensation disclosure for the fiscal year ended December 31, 2018.

FirstName LastNameAnn Hand Comapany NameSuper League Gaming, Inc. February 5, 2019 Page 2 FirstName LastName Ann Hand Super League Gaming, Inc. February 5, 2019 Page 2 Exhibits 3.We note that you have submitted an application for confidential treatment relating to exhibits 10.7 through 10.9 that is currently pending. Please be advised that we will not be in a position to accelerate the effectiveness of your registration statement until we have completed processing your confidential treatment request. 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. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. You may contact Heather Clark at 202-551-3624 or Melissa Raminpour, Accounting Branch Chief, at 202-551-3379 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

Show Raw Text
February 5, 2019
Ann Hand
Chief Executive Officer
Super League Gaming, Inc.
2906 Colorado Ave.
Santa Monica, CA 90404
Re:Super League Gaming, Inc.
Registration Statement on Form S-1
Filed January 4, 2019
File No. 333-229144
Dear Ms. Hand:
            We have reviewed your 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-1 filed January 4, 2019
Our Business, page 54
1.We note your response to prior comment 3 from our letter dated November 11, 2018.
Please expand to clarify that the chart titled “Twitch & YouTube Gaming have a larger
audience than many entertainment platforms” reports annual audience figures as of the
end of 2016 for each platform.
Executive Compensation, page 85
2.Please revise to include executive compensation disclosure for the fiscal year ended
December 31, 2018.

 FirstName LastNameAnn Hand
 Comapany NameSuper League Gaming, Inc.
 February 5, 2019 Page 2
 FirstName LastName
Ann Hand
Super League Gaming, Inc.
February 5, 2019
Page 2
Exhibits
3.We note that you have submitted an application for confidential treatment relating to
exhibits 10.7 through 10.9 that is currently pending. Please be advised that we will not be
in a position to accelerate the effectiveness of your registration statement until we have
completed processing your confidential treatment request.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Heather Clark at 202-551-3624 or Melissa Raminpour, Accounting
Branch Chief, at 202-551-3379 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