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    1345 AVENUE OF THE AMERICAS, 11TH FLOOR

NEW YORK, NEW YORK 10105

TELEPHONE: (212) 370-1300

FACSIMILE: (212) 370-7889

www.egsllp.com

VIA EDGAR

December 21, 2022

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attn: Kathleen Krebs, Special Counsel

 Re: Fig Publishing, Inc.

Amendment No. 1 to

Offering Statement on Form 1-A

Filed October 19, 2022

File No. 024-12017

Dear Ms. Krebs:

On behalf of our client, Fig Publishing, Inc. (the “Company”),
we hereby provide responses to the comments received in the letter dated November 22, 2022 from the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the Company’s Amendment No.
1 to Draft Offering Statement on Form 1-A (the “Offering Statement”) received by the Commission on October 19, 2022.
Disclosure changes discussed below have been made in the Company’s Amendment No. 2 to Draft Offering Statement (the “Amended
Offering Statement”) that is being filed with the Commission contemporaneously with the submission of this letter. Capitalized
terms used herein have the meaning given to such terms in the Amended Offering Statement.

For the Staff’s convenience, we have repeated below in bold each
of the Staff’s comments and have followed each comment with the Company’s response. Capitalized terms used but not defined
herein are used as defined in the Offering Statement (or, if a change has been made to the definition, as defined in the Amended Offering
Statement).

Amendment No. 1 to Draft Offering Statement
on Form 1-A

Management’s Discussion and Analysis of Financial Condition and
Results of Operations

Contractual Commitments, page 36

 1. For each offering under Regulation A, please disclose each licensed product, the amount of Fig Funds provided for each licensed
product and the amount of Fig Gaming Shares or Fig Portfolio Shares sold. Consider providing this information in a table.

In response to this comment, the Company has amended its
disclosure on page 36 by adding a table which lists each licensed product, the amount of Fig Funds provided for each of such licensed
products and the amount of Fig Gaming Shares or Fig Portfolio Shares sold in relation to the provision of Fig Funds for such licensed
product.

 2. For each Regulation A offering where the company will return offering proceeds not used as Fig Funds, disclose the amount of proceeds
currently in escrow and the date by which the proceeds must be used or returned to investors.

In response to this comment, the Company has amended its
disclosure by adding a table on page 36 which provides the amount of proceeds currently in escrow and the date by which the proceeds must
be used or returned to investors for each of Fig Portfolio Shares – Series 2021 and Fig Gaming Shares – Digital Eclipse.

 3. You disclose that you terminated the license agreement with Marauder and that investors who had entered into subscription agreement
had their funds were returned. You then state the following: “During calendar year 2022, we entered into an additional license agreement
for which we are currently raising capital via securities offerings pursuant to Tier 2 of Regulation A.” Please clarify to what offering
this sentence relates.

In response to this comment, the Company has deleted the
referenced sentence in the Amended Offering Statement, as it was erroneously included in the Offering Statement.

General

 4. Please provide consistent disclosure throughout your offering circular of the number of FGS-Atari shares being offered and the
offering price. For example, the fourth paragraph on the initial offering circular cover page indicates you are offering a maximum of
15,000 FGS-Atari at $500 per share, the offering circular cover page of Schedule Atari indicates you are offering a maximum of 30,000
FGS-Atari at $500 per share, and the summary of the use of proceeds on page Atari-4 indicates that you expect an maximum of $15 million
of proceeds assuming all 25,000 of the FGS-Atari shares are sold at the offering price of $1,000 per share.

In response to this comment the Company has revised its disclosure
throughout the Amended Offering Statement to clarify that a maximum of 30,000 FGS-Atari shares are intended to be offered at $500 per
share upon the qualification of the Amended Offering Statement.

 5. Please revise your disclosure throughout the Schedule Atari to accurately and consistently describe the terms of the Fig Revenue-Sharing
Agreement between the company and Atari Interactive, Inc. Examples include the following:

 ● The disclosure on page Atari-10 regarding the calculation of Fig’s Revenue Share, including the Tier 2 Calculation rate and time
period, is not consistent with the terms of the Fig Revenue-Sharing Agreement. The Tier 2 Calculation rate is also incorrect on pages
Atari-26 and Atari-29.

 ● You sometimes refer to the developer as Small Impact Games rather than Atari; and

 ● In the revenue sharing formula on page Atari-9, Atari Incidental Deductions are subtracted from Revenue from Atari Product. You
indicate that Atari’s Incidental Deductions are uncapped. There is no reference to Atari Incidental Deductions in the Fig Revenue-Sharing
Agreement with Atari Interactive, Inc.

These are just examples. Please revise as appropriate.

In response to this comment the Company has revised its disclosure
throughout the Amended Offering Statement to (i) conform the Tier 2 Calculation rate and time period applicable thereto, (ii) remove erroneous
references to Small Impact Games which now state Atari and (iii) remove erroneous language in reference to the Fig Revenue-Sharing Agreement.

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 6. Please discuss the implications of the Fig Shares Termination Date, which is 60 months after the date that is the earlier of (i)
the date that the final Licensed Game under the Fig Revenue-Sharing Agreement is published or (ii) December 1, 2022. For example, disclose
that the maximum period that holders of FGS-Atari could receive dividends is until December 1, 2027. Furthermore, although the company
must return offering proceeds that are not used in connection with the Fig Revenue-Sharing Agreement within two years after the last closing
of the offering, this means that proceeds could be contributed as Fig Funds to Atari for up to three-and-a-half years into the five-year
term. Since it may take several years for any Licensed Game(s) to be developed and start generating revenues, holders of FGS-Atari shares
may not receive dividends prior to December 1, 2027, even though the Licensed Game(s) may ultimately become commercially successful through
funding with Fig Funds.

In response to this comment, the Company has revised its
disclosure on the cover page as well as pages Atari – 5 and Atari – 10 to discuss the implications of the Fig Shares Termination
Date, which is 60 months after the date that is the earlier of (i) the date that the final Licensed Game under the Fig Revenue-Sharing
Agreement is published or (ii) March 1, 2023. In addition, the Company has made necessary revisions to inform prospective holders of FGS
- Atari shares may not receive dividends prior to March 1, 2028, even though the Licensed Game(s) may be funded with Fig Funds and ultimately
may become commercially successful.

 7. Refer to the last column in the Illustrative Revenue Sharing and Dividend Example on page Atari-11. The dividends per share amount
does not appear to be correctly calculated for 6,000 outstanding shares of FGS-Atari. Please advise and revise as appropriate.

In response to this comment, the Company has corrected the
calculation for 6,000 outstanding shares of FGS – Atari in the Illustrative Revenue Sharing and Dividend Example on page Atari –
11.

 8. Refer to the graph illustrating potential cumulative dividends on page Atari-21. Please clarify the assumed time period of “estimated
lifetime distributions” in light of the Fig Share Termination Date. In addition, explain why there are other blue point on the graph
that do not correspond to example points.

In response to this comment, the Company has revised its
disclosure by replacing the graph illustrating potential cumulative dividends on page Atari – 21, with such graph disclosing the
assumed time period of “estimated lifetime distributions” in light of the Fig Share Termination Date and removing erroneously
placed blue points on the Offering Statement’s prior graph.

 9. Refer to the table under “Historical Results” on page Atari-22. Please explain why you present “Assumed Gross Sales
Revenue” when you are presenting historical results. Also explain why footnotes 2, 3 and 4 to the table refer to Atari products.
Lastly, please clarify, if true, that no games or other products have been released under license agreements relating to prior offerings
of Fig Gaming Shares or Fig Portfolio Shares under Regulation A.

In response to this comment, the Company has revised its
disclosure by removing the table and disclosures on Atari – 22, 23 and 24 as they are not pertinent to the FGS – Atari Offering.

 10. Please explain the purpose of the tables on page Atari-23 and Atari-24 and how they relate to the offering of FGS-Atari and the
Fig Revenue-Sharing Agreement with Atari.

As noted in the Company’s response to comment
10, the Company has revised its disclosure by deleting these tables..

 11. Refer to the description of Atari and Atari Products on pages Atari-16 to Atari-19. Please revise this disclosure to focus on information
that would be material to investors in FGS-Atari shares regarding Atari Interactive, Inc. as the counter-party to the Fig Revenue- Sharing
Agreement. Please consider the following when revising your disclosure:

 ● Clearly indicate which entity you are discussing. For example, it appears you use “Atari” to refer to various Atari entities,
you refer to “the Company” without explaining which company, and it should be clear where you are discussing the party to the
Fig Revenue-Sharing Agreement -- Atari Interactive, Inc.

 ● Clarify in what entity Wade J. Rosen has an ownership interest and what role he will play in connection with the Fig Revenue-Sharing
Agreement.

 ● Clarify why it is material to investors in FGS-Atari shares to know detailed information about the board of directors of Atari.

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 ● You indicate that Atari will need to secure agreements with third-party developers to have games developed. Explain how the Fig
Revenue-Sharing Agreement takes into account Atari’s use of third-party developers and the costs of these developers when determining
Gross Receipts and Fig Revenue Share.

 ● Explain how you calculated “a collective 70% return-on-investment after less than a year on the market” for Atari’s Recharged
series of games and how this information is relevant to investors in FGS-Atari shares.

In response to this comment, the Company has made the following
revisions to its disclosure on pages Atari – 16 through Atari – 19:

 ● Clearly indicated which entity is being discussed;

 ● Clarified that Wade J. Rosen has no ownership interest in the Company and will act as a representative of Atari with respect to the
Fig Revenue-Sharing Agreement;

 ● Clarified to prospective investors in FGS – Atari that Atari has requested that they know detailed information about the board
of directors of Atari; and

 ● Explains how the Fig Revenue-Sharing Agreement takes into account Atari’s use of third-party developers and the costs of these developers
when determining Gross Receipts and Fig Revenue Share; and

 ● Removes the claim that Atari saw “a collective 70% return-on-investment after less than a year on the market” for Atari’s
Recharged series of games.

 12. Refer to the disclosure about how you will select Atari Products on page Atari-20. This disclosure does not appear to represent
how you will mutually agree on Licensed Games with Atari or use particular Atari intellectual property set forth in the Fig Revenue-Sharing
Agreement. Please revise as appropriate.

In response to this comment, the Company has provided additional
disclosure on page Atari – 20 to represent how the Company and Atari will mutually agree on Licensed Games or use particular Atari
intellectual property set forth in the Fig Revenue-Sharing Agreement.

We thank the Staff in advance for its consideration of the
foregoing. Should you have any questions, please do not hesitate to contact me on 978-844-1486 (mobile) or at my email address, aain@egsllp.com.

    Very truly yours,

    /s/ Anthony Ain

    Anthony Ain

    cc:
    Chuck Pettid

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