SEC Comment Letter 0000000000-23-004034 to Nexxen International Ltd. (NEXN)
Nexxen International Ltd.
Date: April 21, 2023 · CIK: 0001849396 · Accession: 0000000000-23-004034
AI Filing Summary & Sentiment
File numbers found in text: 001-40504
Letter
United States securities and exchange commission logo April 21, 2023 Sagi Niri Chief Financial Officer Tremor International Ltd. 82 Yigal Alon Street Tel Aviv, Israel, 6789124 Re:Tremor International Ltd. Form 20-F for the year ended December 31, 2022 Filed March 7, 2023 Form 6-K Submitted March 7, 2023 File No. 001-40504 Dear Sagi Niri: We have reviewed your April 19, 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 March 29, 2023 letter. Form 6-K Submitted March 7, 2023 General 1.Your response to prior comment 8 indicates that CTV spend and PMP spend represent sales in the Connected TV and private marketplace markets; however, you also note that they are non-GAAP measures that are derived from Contribution ex-TAC. As Contribution ex-TAC is a profit measure that is derived from GAAP gross profit it is unclear how "spend", a sales measure, is derived from Contribution ex-TAC. Please advise. Also, as previously requested, please provide us with your proposed disclosures.
FirstName LastNameSagi Niri Comapany NameTremor International Ltd. April 21, 2023 Page 2 FirstName LastName Sagi Niri Tremor International Ltd. April 21, 2023 Page 2 You may contact Christine Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions. Sincerely, Division of Corporation Finance Office of Technology cc: Amy Rothstein
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United States securities and exchange commission logo
April 21, 2023
Sagi Niri
Chief Financial Officer
Tremor International Ltd.
82 Yigal Alon Street
Tel Aviv, Israel, 6789124
Re:Tremor International Ltd.
Form 20-F for the year ended December 31, 2022
Filed March 7, 2023
Form 6-K Submitted March 7, 2023
File No. 001-40504
Dear Sagi Niri:
We have reviewed your April 19, 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 March 29,
2023 letter.
Form 6-K Submitted March 7, 2023
General
1.Your response to prior comment 8 indicates that CTV spend and PMP spend
represent sales in the Connected TV and private marketplace markets; however, you also
note that they are non-GAAP measures that are derived from Contribution ex-TAC.
As Contribution ex-TAC is a profit measure that is derived from GAAP gross profit it is
unclear how "spend", a sales measure, is derived from Contribution ex-TAC. Please
advise. Also, as previously requested, please provide us with your proposed disclosures.
FirstName LastNameSagi Niri
Comapany NameTremor International Ltd.
April 21, 2023 Page 2
FirstName LastName
Sagi Niri
Tremor International Ltd.
April 21, 2023
Page 2
You may contact Christine Dietz, Senior Staff Accountant, at (202) 551-3408 if you have
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Amy Rothstein