SEC Comment Letter 0000000000-23-005067 to Nexxen International Ltd. (NEXN)
Nexxen International Ltd.
Date: May 12, 2023 · CIK: 0001849396 · Accession: 0000000000-23-005067
AI Filing Summary & Sentiment
File numbers found in text: 001-40504
Referenced dates: May 24, 2021
Letter
United States securities and exchange commission logo May 12, 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 May 4, 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 April 21, 2023 letter. Form 6-K Submitted March 7, 2023 General 1.We note your response to prior comment one. It appears that spend, a non-IFRS revenue measure, changes the recognition and measurement principles required to be applied in accordance with IFRS and would therefore be considered individually tailored. In this regard, we note that presenting a non-IFRS measure of revenue that deducts transaction costs as if the company acted as an agent in the transaction, when gross presentation as a principal is required by IFRS would violate Rule 100(b) of Regulation G. Please revise to remove CTV spend and PMP spend from your Form 6-K. Also, please refer to your response to comment number 7 in your letter dated May 24, 2021 regarding presentation of net revenue.
FirstName LastNameSagi Niri Comapany NameTremor International Ltd. May 12, 2023 Page 2 FirstName LastName Sagi Niri Tremor International Ltd. May 12, 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
May 12, 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 May 4, 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
April 21, 2023 letter.
Form 6-K Submitted March 7, 2023
General
1.We note your response to prior comment one. It appears that spend, a non-IFRS revenue
measure, changes the recognition and measurement principles required to be applied in
accordance with IFRS and would therefore be considered individually tailored. In this
regard, we note that presenting a non-IFRS measure of revenue that deducts transaction
costs as if the company acted as an agent in the transaction, when gross presentation as a
principal is required by IFRS would violate Rule 100(b) of Regulation G. Please revise to
remove CTV spend and PMP spend from your Form 6-K. Also, please refer to your
response to comment number 7 in your letter dated May 24, 2021 regarding presentation
of net revenue.
FirstName LastNameSagi Niri
Comapany NameTremor International Ltd.
May 12, 2023 Page 2
FirstName LastName
Sagi Niri
Tremor International Ltd.
May 12, 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