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CORRESP
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CORRESP

 Ross M. Leff, P.C.

To Call Writer Directly:
+1 212 446 4947

ross.leff@kirkland.com

  601 Lexington Avenue

 New York, NY 10022

 United States

 +1 212 446 4800

 www.kirkland.com

Facsimile:
+1 212 446 4900

 August 14, 2024

VIA EDGAR

 Securities and Exchange Commission

Division of Corporation Finance

 Office of Trade &
Services

 100 F Street, NE

 Washington, D.C. 20549

Attn: Robert Shapiro and Doug Jones

Re:
 Genius Sports Limited

Form 20-F for Fiscal Year Ended December 31, 2023

File No. 001-40352

 Ladies and
Gentlemen:

 On behalf of our client, Genius Sports Limited (the “Company”), this letter sets forth the response of the Company to the comments of
the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in your letter dated July 17, 2024, with respect to the above referenced Form 20-F for the
year ended December 31, 2023.

 The text of the Staff’s comment has been included in this letter for your convenience, and we have numbered the
paragraphs below to correspond to the number in the Staff’s letter. For your convenience, we have also set forth the Company’s response immediately below the numbered comment.

Pursuant to 17. C.F.R. § 200.83 (“Rule 83”), we are requesting confidential treatment for portions of our response below, as indicated by
“[***]”, reflecting information that we have provided supplementally to the Commission.

 Form 20-F for Fiscal Year Ended December 31,
2023

 Item 5. Operating and Financial Review and Prospects

Key Components of Revenue and Expenses

Revenue

 Betting Technology, Content and
Service, page 58

1.
 Please explain to us how your customers’ “gross gaming revenue” (“GGR”) measure is
determined and how it establishes the associated profit-sharing percentage and/or amount of contractual minimum revenue guarantees. Also, it appears GGR is a metric that you use. Accordingly, disclose how this metric is used by you with respect to
your business and why it provides useful information to investors regarding your business. Refer to Release No. 33-10751.

Austin Bay
Area  Beijing  Boston  Brussels  Chicago  Dallas  Hong Kong  Houston  London  Los
Angeles  Miami  Munich  Paris  Riyadh  Salt Lake City  Shanghai  Washington, D.C.

FOIA CONFIDENTIAL TREATMENT REQUESTED BY

GENIUS SPORTS LIMITED

PURSUANT TO RULE 83

(GSL-1)

 August 14, 2024

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 Response: The Company respectfully acknowledges the Staff’s comment and advises that Gross Gaming
Revenue (“GGR”) is defined as the amounts wagered by customers less amounts paid out as winnings to customers. The Company’s customers report their GGR to the Company in order to calculate the amount owed to the Company. The Company
then takes the GGR reported by the customers and applies the applicable profit-sharing percentages and/or minimum revenue guarantees to determine the amounts owed to the Company.

The Company establishes the associated profit-sharing percentages and/or amount of contractual minimum revenue guarantees based on the terms in the applicable
customer agreements. The profit-sharing percentages applied to the GGR is contractually agreed to between the Company and its customers. Generally, customer contracts also include minimum revenue guarantees, which are contractually agreed to between
the Company and its customers.

 The Company uses GGR to determine the amounts customers owe the Company as part of its variable Betting Technology,
Content and Services revenue contracts. As described above, in these agreements, the Company receives a percentage share of customer GGR, or net gaming revenue (“NGR”, NGR is a metric derived from GGR). If the percentage share of GGR is
below the minimum revenue guarantee threshold, the Company would be entitled to the minimum revenue guarantee. GGR or expected GGR is also used by the Company as an input to its financial models and forecasts. Specifically, when forecasting revenue,
particularly for customers in the U.S. market, GGR is used in an external industry model to understand the overall market size and opportunity.

 To
illustrate an example of the future purpose and use of disclosures related to GGR, the Company has provided proposed enhancements to its fiscal year 2023 disclosures set forth in Item 5. Operating and Financial Review and Prospects, Key
Components of Revenue and Expenses, Revenue (changes are marked for convenience) that the Company will provide on a prospective basis:

Betting Technology, Content and Services — revenue is primarily generated through the delivery of official sports data for in-game
and pre-match betting and outsourced bookmaking services through the Genius’ proprietary sportsbook platform. Customers access Genius’ sportsbook platform and associated services through the cloud over the contract term. Customer contracts
are typically either on (i) a “fixed” basis, requiring customers to pay a guaranteed minimum recurring fee for a specified number of events, with incremental per-event fees thereafter, or (ii) a “variable” basis, based
on a percentage share of the customer’s Gross Gaming Revenue (“GGR”), typically with minimum payment guarantees. GGR represents the difference between the amount of money players wager and the amount that they win. The Company uses
GGR to determine the amounts customers owe the Company and GGR is generally used by the gambling and betting industry to measure the industry’s growth, market size, and opportunities. Minimum guarantee amounts are

 FOIA CONFIDENTIAL
TREATMENT REQUESTED BY

 GENIUS SPORTS LIMITED

PURSUANT TO RULE 83

(GSL-2)

 August 14, 2024

  Page
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generally recognized over the life of the contract on a straight-line basis, while generally variable fees based on profit sharing and per event overage fees are recognized as earned. Genius
believes that its minimum payment guarantees provide for enhanced revenue visibility while the variable component of its contracts benefits Genius as its partners grow.

Non-GAAP Financial Measures

 Adjusted
EBITDA, page 60

2.
 You state the adjustment for “Litigation and related costs” includes mainly legal and related
costs in connection with non-routine litigation, yet the adjustment appears for each year presented. Please explain to us and disclose to the extent meaningful your rationale for this adjustment. Refer to Question 100.01 of the Compliance and
Disclosure Interpretations on Non-GAAP Financial Measures.

 Response: The Company respectfully acknowledges the Staff’s
comment and advises that the costs included in the “Litigation and related costs” adjustment to adjusted EBITDA are not viewed by the Company as a normal and recurring part of its business operations, as each case is unique and relates to
matters that are not part of the day-to-day operations of the Company’s business. That is, litigation matters that are part of the Company’s day-to-day operations are expensed as part of our on-going operations and included in general and
administrative expenses but are not adjusted for in calculating adjusted EBITDA. The Company considers litigation involving vendors, customers, or employees to be in the ordinary course of business whereas each litigation matter for which expenses
are included in “Litigation and related costs” adjustment is related to a discrete and unique set of facts that are not part of the Company’s normal and continued business activity.

The adjustments primarily relate to litigation involving Sportradar and BetConstruct that began in 2020 as well as new litigation from cases beginning in the
fourth quarter of 2023 involving historical merger and acquisitions (“M&A”) transactions, including the Special Purpose Acquisition Company (“SPAC”) merger that was consummated on April 20, 2021. Historically, litigation
has been infrequent and outside the ordinary course of our operations and, as summarized in the preceding sentence, the litigation included in the adjustment relates to M&A transactions and other one-off, specific cases which are not expected to
repeat such that they are not part of the Company’s normal, recurring business operations.

 The matters related to Sportradar and BetConstruct were
previously disclosed in the Company’s Form 20-F for Fiscal Year Ended December 31, 2022. For reference, the following is a summary of each litigation:

Sportradar

 The
Sportradar litigation began in February 2020 following Sportradar AG and Sportradar UK Limited (collectively, “Sportradar”) filing a claim against Football DataCo Limited (“Football DataCo”), Betgenius Limited
(“Betgenius”), a subsidiary of the Company, and the Company. Sportradar claimed that the Company breached Article 101 of the Treaty on the Functioning of the European Union and Chapter I of the Competition Act 1998 in connection with the
Company’s

 FOIA CONFIDENTIAL
TREATMENT REQUESTED BY

 GENIUS SPORTS LIMITED

PURSUANT TO RULE 83

(GSL-3)

 August 14, 2024

  Page
 4
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exclusive official live data agreement (the “Football DataCo Agreement”) with Football DataCo. In October 2022, the litigation was resolved and Football DataCo was able to continue to
license and market Football DataCo data and the Company maintained the exclusive right to provide low latency Official FDC betting data rights through 2024.

BetConstruct

 In
March 2020, the Company filed a claim against Soft Construct (Malta) Limited (d/b/a BetConstruct) (“BetConstruct”) and its affiliates, Royal Panda Limited and Vivaro Limited for infringing the Company’s database rights by copying and
using the contents of the Company’s databases. The litigation was resolved in December 2022 whereby the Company and BetConstruct agreed to a settlement.

Both of the above litigation matters began in the first quarter of 2020 and were resolved in the fourth quarter of 2022. However, the Company still incurred
costs to action the resolution for these matters during fiscal year 2023.

 The Company also became involved in new litigation in the fourth quarter of
fiscal year 2023 related to patent infringement and historical M&A transactions, including the SPAC merger as follows:

Sportscastr Litigation

On October 5, 2023 Sportscastr Inc. (d/b/a Panda Interactive) (“Sportscastr”) filed a claim against the Company claiming the
Company is infringing patents held by Sportscastr relating to the provision of synchronized live data and content within live video streams. This litigation is currently on-going.

Spirable Litigation

On November 15, 2023, sellers in the Spirable acquisition (“the Claimants”) filed a claim against Genius Sports UK Limited, a
subsidiary of the Company. The claim relates to a dispute following the purchase of Photospire Limited by Genius Sports UK Limited and contingent consideration (earn out) arising from that transaction. This litigation is currently on-going.

DMYII Litigation

On September 12, 2023 a claim was filed against DMYII (SPAC that merged with the Genius legacy business to create Genius Sports Limited)
and the directors of DMYII. The claim relates to matters pre-merger. This litigation is currently on-going.

 As mentioned above, the Company believes
these types of litigation matters are not part of its normal, recurring operations. The Company has considered the information contained in Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations and determined
that the adjustments are appropriate.

 FOIA CONFIDENTIAL
TREATMENT REQUESTED BY

 GENIUS SPORTS LIMITED

PURSUANT TO RULE 83

(GSL-4)

 August 14, 2024

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 B. Liquidity and Capital Resources

Operating Cash Flows, page 65

3.
 Please provide a quantitative and qualitative analysis that explains the increase in the reported amount of
operating cash flows between fiscal 2023 and 2022, including material changes in underlying individual items contributing to the change, like, for example, working capital. Note merely citing changes in results, working capital items, and noncash
items reported in the statement of cash flows may not provide a sufficient basis to understand changes in operating cash between periods. Refer to Item 5 of Form 20-F, in particular the introductory paragraph thereof and instructions 1 and 9
of Instructions to Item 5, section III.D of Release No. 33-6835, section IV.B and B.1 of Release No. 33-8350 and Release No. 33-10890 for guidance.

Response: The Company respectfully acknowledges the Staff’s comment. We have reviewed Item 5 of Form 20-F, specifically the guidance
provided by the introductory paragraph of Item 5 and instructions 1 and 9 of Instructions to Item 5, as well as section IIII.D of Release No. 33-6835, section IV.B and B.1 of Release No. 33-8350 and Release No. 33-10890.
In future filings, the Company will enhance its disclosures to include quantitative and qualitative analysis of material factors affecting the reported amount of net operating cash flows between periods, including where material changes offset one
another.

 To illustrate an example of the future disclosure to address such items, the Company has provided proposed enhancements to its fiscal year 2023
explanations of changes in net operating cash flows as set forth in Item 5. Operating and Financial Review and Prospects, B. Liquidity and Capital Resources section of our Form 20-F for the year ended December 31, 2023. The Company
proposes to provide on a prospective basis enhancements for the fiscal year ended December 31, 2024 (changes are marked for convenience) as follows:

Net cash provided by operating activities was $14.9 million and net cash used in operating activities was $3.5 million in the year ended
December 31, 2023 and 2022, respectively. In the year ended December 31, 2023, sustained revenue growth of 21% and improved trading performance from our Betting Technology, Content and Services and Media Technology, Content and Services
contributed to a $96.1 million decrease in net loss compared to the year ended December 31, 2022. The benefit of the decrease in net loss was partially offset by a decrease in non-cash items of $33.6 million, which was primarily due to
decreases in stock-based compensation of $54.5 million, offset by higher depreciation and amortization of $8.8 million as well as a $11.2 million loss on abandonment of assets. The change in working capital in 2023 of $25.8 million, as compared to
2022, is primarily due to a significant increase in accounts receivable of $33.2 million, partially offset by an increase in accounts payable of $22.1 million, both resulting from the growth in operations in 2023 primarily related to our Betting
Technology, Content and Services and Media Technology, Content and Services. Prepaid expenses also increased during 2023 by $8.6 million due to higher data rights costs. net cash provided by operating activities primarily reflected
Genius’ net loss net of non-cash items of $40.7 million, offset by changes in working capital of $25.8 million. In the year ended December 31, 2022, net cash used in operating activities primarily reflected Genius’ net loss net of
non-cash items of $21.8 million, offset by changes in working capital of $18.4 million.

 FOIA CONFIDENTIAL
TREATMENT REQUESTED BY

 GENIUS SPORTS LIMITED

PURSUANT TO RULE 83

(GSL-5)

 August 14, 2024

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 6
 of 17

 E. Critical Accounting Estimates

Revenue Recognition, page 66

4.
 You disclose for Sports Technology and Services you primarily receive noncash consideration for which there
is not a readily determinable fair value and for Betting Technology, Content and Services in regard to contracts with variable consideration associated with overages you record cumulative effect adjustments when there are constraint changes that
impact your estimate of the transaction price. Please provide qualitative and quantitative information necessary to understand the estimation uncertainty associated with each rev