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    rwernli@sheppardmullin.com

April
27, 2020

VIA
EDGAR AND ELECTRONIC MAIL

Edwin
Kim, Esq.

Division
of Corporation Finance

United
States Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    GAN
    Limited

    Registration
    Statement on Form F-1

    Initially
    Filed March 25, 2020

    File
    No. 333-237372

Ladies
and Gentlemen:

We
are writing on behalf of GAN Limited (the “Company”) in response to comments from the staff of the Division
of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
relating to the above-referenced filing. The Company is concurrently filing an Amendment No. 2 to Registration Statement on Form
F-1 (the “Registration Statement”).

In
response to comments from the Staff, the Company has made the following revisions to the Registration Statement:

1.
The Company moved the introductory discussion of the Reorganization and Share Exchange from the About this Prospectus section
to the Prospectus Summary. The Company also added additional disclosure concerning the termination of trading of GAN plc shares
on the AIM market. See page 9 of the Registration Statement.

2.
The Company moved the About this Prospectus section to the end of the prospectus, except as provided in item 1 above. See page
123 of the Registration Statement.

3.
In the section Principal Shareholders, the Company revised the beneficial ownership table to identify the individual that controls
the voting and disposition of the ordinary shares held by each 5% stockholder and to include the address of each 5% shareholder.
See page 85 of the Registration Statement.

4. The Company has added
disclosure in the Management Discussion and Analysis section that FanDuel represented 15% of revenues in 2018,
and to discuss the basis for the change in revenue from 2018 and 2019. See page 56 of the Registration Statement.

5. The Company revised
its guidance disclosure in the Management Discussion and Analysis to include available Q1 Flash numbers, and to describe the basis
on which the Company has developed its full year 2020 revenue guidance. The Company also added additional cautionary language
concerning its forward-looking estimates. See pages 14 and 54 of the Registration Statement.

6. The Company has
revised its disclosure concerning revenue recognition to clarify that revenue is recognized using a usage-based model at the time
of settlement of an event for real-money iGaming or at the time of purchase for in-game credit for simulated iGaming. See pages
48 and F-12 of the Registration Statement.

7. The Company has
revised the disclosures related to its Segment Results in Management Discussion and Analysis to eliminate references to totals
or metrics that would constitute non-IFRS measures. See pages 56 of the Registration Statement.

*
* * * *

     -1-

We
sincerely appreciate the Staff’s comments. If you have any additional questions or need any information, please do not hesitate
to contact us by phone or email at the addresses listed above.

    Sincerely,

    /s/
    James A. Mercer III, Esq.

    James
    A. Mercer III, Esq.

    /s/
    Robert L. Wernli, Jr., Esq.

    Robert
    L. Wernli, Jr., Esq.

    cc:
    Mr.
    Dermot Smurfit, GAN Limited

    Ms.
    Karen Flores, GAN Limited

    Sara
    Terheggen, Esq., The NBD Group.

     -2-