SEC Comment Letter 0000000000-23-006649 to Sportradar Group AG (SRAD)
Sportradar Group AG
Date: June 22, 2023 · CIK: 0001836470 · Accession: 0000000000-23-006649
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo June 22, 2023 Gerard Griffin Chief Financial Officer Sportradar Group AG Feldistrasse 2 CH-9000 St. Gallen, Switzerland Re:Sportradar Group AG Form 20-F for the Year Ended December 31, 2022 Filed on March 15, 2023 Form 6-K Submitted on May 10, 2023 Dear Gerard Griffin: We have reviewed your May 30, 2023 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our May 16, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 Non-IFRS Financial Measures and Operating Metrics, page 79 1.We note your response to prior comment 2 and that the adjustment “foreign currency gains on cash equivalents” represents the exchange rate movement on certain cash equivalents, specifically, your investments in U.S. Dollar money market funds. While the effect of exchange rate fluctuation on cash held in foreign currencies affects the cash balance during a period, it does not represent cash receipts or payments. The impact of exchange rate fluctuation does not give rise to cash flows, therefore, such adjustment does not appear to be appropriate in determining a non-GAAP measure of cash flows. Please refer to paragraph 28 of IAS 7 and revise accordingly.
FirstName LastNameGerard Griffin Comapany NameSportradar Group AG June 22, 2023 Page 2 FirstName LastName Gerard Griffin Sportradar Group AG June 22, 2023 Page 2 You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Jason Barr
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United States securities and exchange commission logo
June 22, 2023
Gerard Griffin
Chief Financial Officer
Sportradar Group AG
Feldistrasse 2
CH-9000 St. Gallen, Switzerland
Re:Sportradar Group AG
Form 20-F for the Year Ended December 31, 2022
Filed on March 15, 2023
Form 6-K Submitted on May 10, 2023
Dear Gerard Griffin:
We have reviewed your May 30, 2023 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
May 16, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Non-IFRS Financial Measures and Operating Metrics, page 79
1.We note your response to prior comment 2 and that the adjustment “foreign currency
gains on cash equivalents” represents the exchange rate movement on certain cash
equivalents, specifically, your investments in U.S. Dollar money market funds. While the
effect of exchange rate fluctuation on cash held in foreign currencies affects the cash
balance during a period, it does not represent cash receipts or payments. The impact of
exchange rate fluctuation does not give rise to cash flows, therefore, such adjustment does
not appear to be appropriate in determining a non-GAAP measure of cash flows. Please
refer to paragraph 28 of IAS 7 and revise accordingly.
FirstName LastNameGerard Griffin
Comapany NameSportradar Group AG
June 22, 2023 Page 2
FirstName LastName
Gerard Griffin
Sportradar Group AG
June 22, 2023
Page 2
You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Jason Barr