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 Document August 21, 2025 VIA EDGAR Office of Trade & Services Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Gambling.com Group Limited Registration Statement on Form F-3 File No. 333-289617 Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Gambling.com Group Limited (the “ Company ”), hereby requests that the effective date of the Company’s Registration Statement on Form F-3 (File No. 333-289617) (the “ Registration Statement ”) be accelerated by the Securities and Exchange Commission so that the Registration Statement will become effective at 9:00 a.m., Eastern Daylight Time, on August 25, 2025, or as soon as practicable thereafter.  Sincerely yours, Gambling.com Group Limited By: /s/ Elias Mark Name: Elias Mark Title: Chief Financial Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 20, 2025

Michael Stein
General Counsel
Gambling.com Group Limited
22 Grenville Street
St. Helier, Jersey JE4 8PX Channel Islands

 Re: Gambling.com Group Limited
 Registration Statement on Form F-3
 Filed August 14, 2025
 File No. 333-289617
Dear Michael Stein:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Rucha Pandit at 202-551-6022 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Jessica Chen
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
July 21, 2023
Elias Mark
Chief Financial Officer
Gambling.com Group Limited
22 Grenville Street
St. Helier, Channel Island of Jersey JE4 8PX
Re:Gambling.com Group Limited
Form 20-F for Fiscal Year Ended December 31, 2022
File No. 001-40634
Dear Elias Mark:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
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Document

July 13, 2023

VIA EDGAR

Office of Trade & Services

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re:

 Gambling.com Group Ltd

  Form 20-F for Fiscal Year Ended December 31, 2022

  Filed March 23, 2023

  File No. 001-40634

Ladies and Gentlemen:

This letter is in response to the comment letter, dated June 28, 2023, of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) regarding the above-referenced filing for Gambling.com Group Limited (“Gambling.com Group” or the “Company”).

To assist your review, we have retyped the text of the Staff’s comments in italics below.  References to the “Prior Response Letter” refer to the Company’s responses in the letter dated June 16, 2023, provided in response to the Staff’s initial comment letter, dated June 8, 2023 (the “Prior Staff Letter”).

Form 20-F for Fiscal Year Ended December 31, 2022

Business Overview, page 32

1.We note your response to comment one. Non-GAAP C&DI 102.12 applies to a financial measure or information that is not in accordance with GAAP (in your case IFRS) or calculated exclusively from amounts presented in accordance with GAAP (IFRS). Net income divided by revenue would be calculated exclusively from amounts presented in accordance with IFRS and, therefore, is not subject to C&DI 102.12 and is not prohibited. Please revise to provide disclosure of the most directly comparable IFRS measure with equal or greater prominence. Refer to Item 10(e)(1)(i)(A) of Regulation S-K. We do not object to you reconciling solely Adjusted EBITDA to net income.

Response:

The Company acknowledges the Staff’s comment to the Company’s response in the Prior Response Letter and will revise its future filings to provide disclosure of Net Income margin, Net Income being the Company’s most directly comparable IFRS measure to Adjusted EBITDA, with equal or greater prominence in the Company’s anticipated Report on Form 6-K reporting its financial results for the three- and six-month periods ended June 30, 2023, and subsequent reports, including the Company’s Annual Report on Form 20-F for the year ended December 31, 2023.

1

Item 5. Operating and Financial Review and Prospects

Results of Operations,

Revenues, page 45

2.We note your response to comment two. Please supplementally provide us quantification of the extent to which revenue recognized in each of the last three fiscal years results from referrals in that year or referrals from prior fiscal years.

Response:

The Company acknowledges the Staff’s comment to the Company’s response in the Prior Response Letter, and respectfully submits to the Staff that the Company has ultimately determined that it is not able to obtain the requested supplemental quantification without unreasonable effort because the Company does not maintain data of its periodic revenue split by the timing of specific referrals made.

Notes to Consolidated Financial Statements

Summary of Significant Accounting Policies

Revenue Recognition, page F-15

3.We note your response to comment three. Please revise your disclosure to include an explanation similar to that provided in your response.

Response:

The Company acknowledges the Staff’s comment to the Company’s response in the Prior Response Letter and will revise accordingly in the Company’s anticipated Annual Report on Form 20-F for the year ended December 31, 2023, and subsequent annual reports.

Note 19. Operating Expenses

Sales and Marketing Expenses, page F-43

4.We note your response to comment six. You state external content costs are primarily associated with articles published on your websites. Given that you earn revenue from subscriptions, it is not clear from your response why such costs are not classified as cost of sales. Please advise.

Response:

The Company acknowledges the Staff’s comment to the Company’s response in the Prior Response Letter and respectfully informs the Staff that all costs are classified according to their nature and purpose, as follows:

With regards to the external content cost associated with the creation of articles that are published on the Company’s and its media partnership websites, we note that such content is made available free-of-charge to all website users. Its purpose is to attract visitors to the Company and its media partner’s websites. While such content may attract visitors who ultimately subscribe, no revenue is earned directly from the publication of such articles and such external costs are therefore classified as sales and marketing expense.

Conversely, costs are also incurred with respect to exclusive paid subscription content that provides more in-depth information to the subscriber, such as data analytics and tools for fantasy sports leagues. These costs include data fees, payment processing fees and hosting fees. Such costs are considered to be directly attributable to subscription revenue and are therefore classified as cost of sales.

In order to provide more clarity to readers of the financial statements on the nature of the costs that are classified as either cost of sales or sales and marketing expenses, the Company will enhance its accounting policy relating to cost of sales accordingly in the Company’s anticipated Annual Report on Form 20-F for the year ended December 31, 2023, and subsequent filings, as follows:

“Cost of sales are costs considered directly attributable to the generation of revenue and include, in relation to the generation of performance marketing revenue, license fees incurred as part of agreements with media partners and, in relation to the generation of subscription revenue on certain websites of the Group, data purchases, payment processing fees and hosting fees. Such expenses are recognized as incurred. External content costs associated with the creation of articles that are published on the Company’s and its media partnership websites and made available free-of-charge to all

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website users are not considered costs of sales as no revenue is earned directly from the publication of such articles.”

Please contact the undersigned at (415) 238-6232 with any questions or comments you may have regarding this letter.

  Sincerely yours,

  /s/ Michael J. Stein

  Michael J. Stein

  Vice President, General Counsel

cc:

 Charles Gillespie, Chief Executive Officer, Gambling.com Group Limited

  Elias Mark, Chief Financial Officer, Gambling.com Group Limited

 Joe Lucey, Partner, BDO LLP

3

United States securities and exchange commission logo
June 28, 2023
Elias Mark
Chief Financial Officer
Gambling.com Group Ltd
22 Grenville Street
St. Helier, Channel Island of Jersey JE4 8PX
Re:Gambling.com Group Ltd
Form 20-F for Fiscal Year Ended December 31, 2022
Response dated June 16, 2023
File No. 001-40634
Dear Elias Mark:
            We have reviewed your June 16, 2023 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
June 8, 2023 letter.
Form 20-F for Fiscal Year Ended December 31, 2022
Business Overview, page 32
1.We note your response to comment one.  Non-GAAP C&DI 102.12 applies to a financial
measure or information that is not in accordance with GAAP (in your case IFRS) or
calculated exclusively from amounts presented in accordance with GAAP (IFRS).  Net
income divided by revenue would be calculated exclusively from amounts presented in
accordance with IFRS and, therefore, is not subject to C&DI 102.12 and is not prohibited.
Please revise to provide disclosure of the most directly comparable IFRS measure with
equal or greater prominence.  Refer to Item 10(e)(1)(i)(A) of Regulation S-K.  We do not
object to you reconciling solely Adjusted EBITDA to net income.

 FirstName LastNameElias Mark
 Comapany NameGambling.com Group Ltd
 June 28, 2023 Page 2
 FirstName LastName
Elias Mark
Gambling.com Group Ltd
June 28, 2023
Page 2
Item 5. Operating and Financial Review and Prospects
Results of Operations
Revenues, page 45
2.We note your response to comment two.  Please supplementally provide us quantification
of the extent to which revenue recognized in each of the last three fiscal years results from
referrals in that year or referrals from prior fiscal years.
Notes to Consolidated Financial Statements
Summary of Significant Accounting Policies
Revenue Recognition, page F-15
3.We note your response to comment three.  Please revise your disclosure to include an
explanation similar to that provided in your response.
Note 19. Operating Expenses
Sales and Marketing Expenses, page F-43
4.We note your response to comment six.  You state external content costs are primarily
associated with articles published on your websites.  Given that you earn revenue from
subscriptions, it is not clear from your response why such costs are not classified as cost
of sales.  Please advise.
            You may contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

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Document

June 16, 2023

VIA EDGAR

Office of Trade & Services

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re:

 Gambling.com Group Limited

   Form 20-F for Fiscal Year Ended December 31, 2022

   Filed March 23, 2023

   File No. 001-40634

Ladies and Gentlemen:

This letter is in response to the comment letter, dated June 8, 2023, of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) regarding the above-referenced filing for Gambling.com Group Limited (“Gambling.com Group” or the “Company”). To assist your review, we have retyped the text of the Staff’s comments in italics below.

Form 20-F for Fiscal Year Ended December 31, 2022

Business Overview, page 32

1.We note your disclosure of Adjusted EBITDA margin. Please revise to provide disclosure of the most directly comparable IFRS measure with equal or greater prominence. Refer to Item 10(e)(1)(i)(A) of Regulation S-K.

Response:

The Company respectfully believes that as the disclosure of margins is not a requirement of the system of regulation that is applicable to the Company, IFRS, the creation of a margin such as the quotient of, for example, net income divided by revenue, would itself be a non-GAAP measure, as disclosed in the SEC’s “Compliance & Disclosure Interpretations on Non -GAAP Financial Measures, Question 102.12.”

The Company respectfully believes that the reconciliation of, for example, Net Income margin to Adjusted EBITDA margin, would be a reconciliation from one non-GAAP measure to another non-GAAP measure. The Company respectfully believes that the quantified reconciliation of Net Income to Adjusted EBITDA complies with Item 10(e)(1)(i)(A) of Regulation S-K. Both Regulation G and Item 10(e) of Regulation S-K require that any non-GAAP financial measures be accompanied by a presentation of the most directly comparable GAAP financial measure and a reconciliation of the differences between such measures. The Company believes this is achieved through the reconciliation of Adjusted EBITDA to Net Income, with the computation of the resulting Adjusted EBITDA margin also disclosed. Accordingly, the Company does not believe any incremental disclosure is required related to another non-GAAP measure derived from a GAAP measure.

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Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 45

2.We note your disclosure on page F-15 that revenue-share fees are a percentage of the net gaming revenues an operator generates over the lifetime of the referred player. It is not clear from your disclosure the extent to which revenue recognized in a particular period results from referrals in the current year or referrals from prior years. Please consider whether quantification of revenue from new and pre-existing referrals would provide meaningful information to investors about the duration of your income streams and the extent to which your business relies on new referrals for the maintenance and growth of revenue levels.

Response:

The Company does not believe the quantification of revenue from new and pre-existing referrals would provide meaningful information to investors because the ultimate revenue-sharing fees from such referrals are subject to significant uncertainties, including how long the referred player will remain active, the size and frequency of the wager amounts, and the patterns of wins and losses. These factors vary significantly between markets and products, as well as between individual operators, and are further influenced by competition from other entertainment channels, taxation and regulatory developments, results of various sporting events, disruptive events such as the COVID-19 pandemic, and general economic conditions. As a result, historical revenue from new and pre-existing referrals recognized in a particular period is not indicative of future revenue performance from such new and pre-existing referrals.

Notes to Consolidated Financial Statements Summary of Significant Accounting Policies Revenue Recognition, page F-15

3.You disclose that negative revenue share amounts usually do not carry over into subsequent months. Please describe for us the nature of negative revenue share amounts.

Response:

For the gambling operator, who is the counterparty in a revenue share agreement with the Company, if the referred players, when aggregated together, win amounts greater than the losses they incur during a particular calendar month, this results in negative net revenue for the operator for the applicable period.

Under a revenue share agreement with the operator, such negative net revenue is not typically permitted to be carried forward and offset against net operating revenue earned from the same referred players in subsequent calendar months.

The gambling operator’s negative net revenue yields no revenue share amount for the Company for the applicable period and, as a result, the Company does not recognize revenue in the corresponding period when the operator has negative net revenue. Because such negative revenue yield is not carried forward to subsequent periods, the Company recognizes revenue in subsequent periods without deductions from carried forward negative revenue yield.

For those small number of operators with agreements that do permit the carryforward of negative net revenue, such carryforwards are rare and are immaterial to the Company’s operations.

Note 18. Revenue, page F-41

4.We note that you earn performance marketing fees in the form of ongoing revenue-shares, one-time fees, and a hybrid of these two forms. Please tell us your consideration of disaggregating performance marketing fees along these lines, given the differences in the nature and timing of these forms of fees.

2

Response:

Following the acquisition of RotoWire.com, the Company started to incur subscription revenue in addition to performance marketing revenue. Because the monetization model and revenue recognition of performance marketing revenue and subscription revenue are substantially different, the Company considers it most relevant to disaggregate revenue by the monetization type rather than the disaggregation of the form of fees within performance marketing.

The Company acknowledges the Staff’s comment, however, and will revise its future filings to provide the disclosure pursuant to the comment by inserting the disaggregation of the form of fees (Cost Per Acquisition, revenue share and hybrid) as a percentage of performance marketing revenue in text below the table of disaggregated revenue by monetization type in the notes to the financial statements and “Operating and Financial Review and Prospects” section in the Company’s anticipated Report on Form 6-K reporting its financial results for the three- and six-month periods ended June 30, 2023, and subsequent reports, including the Company’s Annual Report on Form 20-F for the year ended December 31, 2023.

Note 19. Operating Expenses

Sales and Marketing Expenses, page F-43

5.Please explain your consideration of classifying amortization of certain intangible assets as cost of sales instead of 'Sales and marketing expenses.' In this regard, we note you attribute the increase in amortization expense primarily to the acquisition of RotoWire.com and BonusFinder.com in 2022, and their related domain names, apps, and customer contracts on page 49, which appears related to cost of sales. Refer to SAB Topic 11B.

Response:

IAS1 Presentation of Financial Statements (IAS 1) paragraph 99 permits the Company to choose its income statement presentation by function of expenses or nature of expenses.  Under IAS1.103, the Company has opted to present its income statement by function of expenses. As a result of this presentation, the Company includes amortization of certain intangible assets within sales and marketing expense and technology expenses rather than a separate line item for amortization. The Company believes that the function of expenses method provides more relevant information to users than the classification of expenses by nature, notwithstanding that allocating costs to functions may require considerable judgement.

IAS 1 does not provide specific guidance to determine what should be included in “cost of sales.” However, paragraph 38 of IAS 2 Inventories specifies that “cost of sales” should include costs previously included in the measurement of inventory that has now been sold, unallocated production overheads and abnormal amounts of production costs of inventories. Depending on the circumstances of the entity, other amounts, such as distribution costs, may also be included in “cost of sales.” “Cost of sales” should include costs directly associated with fulfilling performance obligations under IFRS 15 Revenue from Contracts with Customers. Considering the nature of the Company’s operations, it was concluded that cost of sales consists of direct costs incurred in the production of goods or services that are sold to customers.

Amortization expense relates to (a) content and customer contracts acquired in connection with the acquisitions of RotoWire.com and BonusFinder.com, and (b) certain capitalized development costs related to the Company’s technology platform. The Company’s technology platform contains tools utilized to attract visitors to the Company’s websites. The acquired content is published on the Company’s websites and utilized to attract visitors. Because the intangible assets are not incurred in the production of goods or services that are sold to customers but rather in the acquisition of visitors and customers, the Company has classified the associated amortization as sales and marketing expense and technology expenses rather than cost of sales.

The Company does not believe any amortization of intangible assets related to its technology platform or acquired content and customer contracts should be included in costs of sales because these assets are not directly related to the generation of revenue.

Finally, the Company respectfully believes that SAB Topic 11B is an accounting bulletin specific to US GAAP and in accordance with SEC Financial Reporting Manual s6320.5 the Company need not comply with such requirements. The Company also respectfully notes to the Staff that in Note 2 Summary of Significant Accounting Policies to the consolidated financial statements, filed in the Annual Report on Form 20-F on March 23, 2023, it provides sufficient disclosure of the material items that comprise Cost of Sales.

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6.Please disclose the nature of external content costs. Also, explain to us your consideration of classification of external content as a component of cost of sales as these costs appear integrally related to your revenue generating activities, particularly for RotoWire and BonusFinder acquired in 2022. In this regard, we note that you earn revenue from subscriptions.

Response:

External content costs are primarily costs associated with articles written by freelance writers purchased by the Company and published on the Company’s websites, including RotoWire.com and BonusFinder.com. These articles are utilized to attract visitors to the Company’s websites. As such, these costs are not incurred in the production of goods or services that are sold to customers and, therefore, the Company classifies these costs as sales and marketing expense rather than cost of sales.

Costs that are directly related to the generation of revenue include license fees incurred as part of agreements with media partners and hosting, data and payment processing fees related to subscription access to the RotoWire.com website. Such costs are classified as cost of sale.

Please contact the undersigned at (415) 238-6232 with any questions or comments you may have regarding this letter.

  Sincerely yours,

  /s/ Michael J. Stein

  Michael J. Stein

  Vice President, General Counsel

cc:

 Charles Gillespie, Chief Executive Officer, Gambling.com Group Limited

  Elias Mark, Chief Financial Officer, Gambling.com Group Limited

4

United States securities and exchange commission logo
June 8, 2023
Elias Mark
Chief Financial Officer
Gambling.com Group Ltd
22 Grenville Street
St. Helier, Channel Island of Jersey JE4 8PX
Re:Gambling.com Group Ltd
Form 20-F for Fiscal Year Ended December 31, 2022
Filed March 23, 2023
File No. 001-40634
Dear Elias Mark:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for Fiscal Year Ended December 31, 2022
Business Overview, page 32
1.We note your disclosure of Adjusted EBITDA margin.  Please revise to provide disclosure
of the most directly comparable IFRS measure with equal or greater prominence.  Refer to
Item 10(e)(1)(i)(A) of Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 45
2.We note your disclosure on page F-15 that revenue-share fees are a percentage of the net
gaming revenues an operator generates over the lifetime of the referred player.  It is not
clear from your disclosure the extent to which revenue recognized in a particular period
results from referrals in the current year or referrals from prior years.  Please consider
whether quantification of revenue from new and pre-existing referrals would provide
meaningful information to investors about the duration of your income streams and the

 FirstName LastNameElias Mark
 Comapany NameGambling.com Group Ltd
 June 8, 2023 Page 2
 FirstName LastName
Elias Mark
Gambling.com Group Ltd
June 8, 2023
Page 2
extent to which your business relies on new referrals for the maintenance and growth of
revenue levels.
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-15
3.You disclose that negative revenue share amounts usually do not carry over into
subsequent months.  Please describe for us the nature of negative revenue share amounts.
18. Revenue, page F-41
4.We note that you earn performance marketing fees in the form of ongoing revenue-shares,
one-time fees, and a hybrid of these two forms.  Please tell us your consideration of
disaggregating performance marketing fees along these lines, given the differences in the
nature and timing of these forms of fees.
Note 19. Operating Expenses
Sales and Marketing Expenses, page F-43
5.Please explain your consideration of classifying amortization of certain intangible assets
as cost of sales instead of 'Sales and marketing expenses.'  In this regard, we note
you attribute the increase in amortization expense primarily to the acquisition of
RotoWire.com and BonusFinder.com in 2022, and their related domain names, apps, and
customer contracts on page 49, which appears related to cost of sales.  Refer to SAB
Topic 11B.
6.Please disclose the nature of external content costs.  Also, explain to us your consideration
of classification of external content as a component of cost of sales as these costs appear
integrally related to your revenue generating activities, particularly for RotoWire and
BonusFinder acquired in 2022. In this regard, we note that you earn revenue from
subscriptions.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

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Document

May 24, 2023

VIA EDGAR

Office of Trade & Services

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: Gambling.com Group Limited

 Registration Statement on Form F-3

 File No. 333-272030

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Gambling.com Group Limited (the “Company”), hereby requests that the effective date of the Company’s Registration Statement on Form F-3 (File No. 333-272030) (the “Registration Statement”) be accelerated by the Securities and Exchange Commission so that the Registration Statement will become effective at 4:00 p.m., Eastern Daylight Time, on May 26, 2023, or as soon as practicable thereafter.

Sincerely yours,

Gambling.com Group Limited

By: /s/ Elias Mark

 Name: Elias Mark

 Title: Chief Financial Officer

United States securities and exchange commission logo
May 24, 2023
Charles Gillespie
Chief Executive Officer
Gambling.com Group Ltd
514 North Franklin St, Suite 201
Tampa, FL 33602
Re:Gambling.com Group Ltd
Registration Statement on Form F-3
Filed May 18, 2023
File No. 333-272030
Dear Charles Gillespie:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Jennie Beysolow at 202-551-8108 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jessica Y. Chen, Esq.

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Document

September 21, 2022

VIA EDGAR

Office of Trade & Services

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re:  Gambling.com Group Limited

        Registration Statement on Form F-3

        File No. 333-266888

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Gambling.com Group Limited (the “Company”), hereby requests that the effective date of the Company’s Registration Statement on Form F-3 (File No. 333-266888) (the “Registration Statement”) be accelerated by the Securities and Exchange Commission so that the Registration Statement will become effective at 4:00 p.m., Eastern Daylight Time, on September 23, 2022, or as soon as practicable thereafter.

                            Sincerely yours,

                            Gambling.com Group Limited

                            By:  /s/ Elias Mark

                                    Name: Elias Mark

                                    Title: Chief Financial Officer

United States securities and exchange commission logo
August 22, 2022
Charles Gillespie
Chief Executive Officer
Gambling.com Group Ltd
c/o GDC America Inc.
514 North Franklin St, Suite 201
Tampa, FL 33602
Re:Gambling.com Group Ltd
Registration Statement on Form F-3
Filed on August 15, 2022
File No. 333-266888
Dear Mr. Gillespie :
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Janice Adeloye at 202-551-3034 or Lilyanna Peyser at 202-551-3222 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

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Underwriter Acceleration Request

 Jefferies LLC

520 Madison Avenue

 New York, New
York, 10022

 VIA EDGAR

 July 22, 2021

 Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Re:
 Gambling.com Group Limited

 Registration Statement on Form F-1 (as amended) (SEC File No. 333-257403)

 Ladies and Gentlemen:

In connection with the above-referenced Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”),
we hereby join in the request of Gambling.com Group Limited that the effective date of the Registration Statement be accelerated so that it will be declared effective at 4:30 p.m., New York City time, on Thursday, July 22, 2021, or as soon
thereafter as practicable.

 Pursuant to Rule 460 of the General Rules and Regulations under the Act, please be advised that we will take reasonable steps
to secure adequate distribution of the preliminary prospectus to underwriters, dealers, institutions and others, prior to the requested effective time of the Registration Statement.

In connection with the Preliminary Prospectus distribution for the above-referenced issue, the prospective underwriters have confirmed that they are complying
with the 48-hour requirement in Rule 15c2-8(b) under the Securities Exchange Act of 1934, as amended.

Very truly yours,

 Jefferies LLC

As Representative of the several underwriters

[SIGNATURE PAGE FOLLOWS]

JEFFERIES LLC

By:

/s/ Ashley Delp Walker

Name: Ashley Delp Walker

Title: Managing Director

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Company Acceleration Request

 GAMBLING.COM GROUP LIMITED

22 Grenville Street, St. Helier

Channel Island of Jersey JE4 8PX

 July 22,
2021

 VIA EDGAR

 United States Securities and
Exchange Commission

 Division of Corporation Finance

 100 F
Street, NE

 Washington, D.C. 20549

Re:
 REQUEST FOR ACCELERATION OF EFFECTIVENESS

Gambling.com Group Limited (CIK No. 0001839799)

Registration Statement on Form F-1 (File
No. 333-257403)

Ladies and Gentlemen:

 Pursuant to Rule 461 of
the rules and regulations promulgated under the Securities Act of 1933, as amended, the undersigned registrant hereby respectfully requests that the effective date for the Registration Statement referred to above be accelerated so that it will be
declared effective at 4:30 p.m. Eastern Daylight Time on Thursday, July 22, 2021 or as soon thereafter as is practicable. In connection with the Registration Statement, the underwriters join in this request for acceleration by separate letter.

 Please contact Jessica Y. Chen at (212) 819-8503 or Charlotte Lan at (212) 819-8642 of White & Case LLP with any questions and please notify one or more of them when this request for acceleration has been granted.

[Remainder of Page Intentionally Blank]

Sincerely,

GAMBLING.COM GROUP LIMITED

 By: /s/ Charles Gillespie

Name: Charles Gillespie

Title: Chief Executive Officer

CORRESP
1
filename1.htm

CORRESP

 Jefferies LLC

520 Madison Avenue

 New York, New
York, 10022

 VIA EDGAR

 July 20, 2021

 Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Re:
 Gambling.com Group Limited

 Registration Statement on Form F-1 (as amended) (SEC File No. 333-257403)

 Withdrawal of Request for Acceleration of Effective Date

Ladies and Gentlemen:

 Reference is made to our letter, filed
as correspondence via EDGAR on July 16, 2021, in which we, as the underwriters of Gambling.com Group Limited’s (the “Company”) proposed initial public offering of ordinary shares, joined the Company’s request for
acceleration of the effective date of the above-named Registration Statement (the “Registration Statement”) for Tuesday, July 20, 2021, at 4:00 p.m., New York City time.

The Company is no longer requesting that such Registration Statement be declared effective at such time and thus we hereby formally withdraw our request for
acceleration of the effective date.

 Very truly yours,

Jefferies LLC

 As Representative of the several underwriters

 [SIGNATURE PAGE FOLLOWS]

JEFFERIES LLC

By:

/s/ Andrew Zarnett

Name:

Andrew Zarnett

Title:

Managing Director

 As representative of the several underwriters.

CORRESP
1
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CORRESP

 GAMBLING.COM GROUP LIMITED

22 Grenville Street, St. Helier

Channel Island of Jersey JE4 8PX

 July 20,
2021

 VIA EDGAR Submission

 Securities and Exchange
Commission

 Division of Corporate Finance

 100 F. Street,
N.E.

 Washington, D.C. 20549

 Attention: Mr. Scott
Anderegg

Re:
 Withdrawal of Request for Acceleration of Effectiveness

 Gambling.com Group Limited (CIK No. 0001839799)

 Registration Statement on Form F-1 (File No. 333-257403)

Ladies and Gentlemen:

 Reference is made to our letter, filed as
correspondence via EDGAR on July 16, 2021, in which we requested the acceleration of the effective date of the above-referenced Registration Statement for July 20, 2021, at 4:00 p.m. Eastern Daylight Time. Based on our telephonic advice to
you through our counsel earlier today, the Company is no longer requesting that such Registration Statement be declared effective at such time and date and we hereby formally withdraw our request for acceleration at the aforementioned effective
date.

 [Remainder of Page Intentionally Blank]

 Sincerely,

GAMBLING.COM GROUP LIMITED

By:

/s/ Charles Gillespie

Name:

Charles Gillespie

Title:

Chief Executive Officer

CORRESP
1
filename1.htm

Underwriter Acceleration Request

 VIA EDGAR

July 16, 2021

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Gambling.com Group Limited

Registration Statement on Form F-1 (as amended) (SEC File
No. 333-257403)

 Ladies and Gentlemen:

In connection with the above-referenced Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the
“Act”), we hereby join in the request of Gambling.com Group Limited that the effective date of the Registration Statement be accelerated so that it will be declared effective at 4:00 p.m., New York City time, on Tuesday,
July 20, 2021, or as soon thereafter as practicable.

 Pursuant to Rule 460 of the General Rules and Regulations under the Act, please be advised that
we will take reasonable steps to secure adequate distribution of the preliminary prospectus to underwriters, dealers, institutions and others, prior to the requested effective time of the Registration Statement.

In connection with the Preliminary Prospectus distribution for the above-referenced issue, the prospective underwriters have confirmed that they are complying
with the 48-hour requirement in Rule 15c2-8(b) under the Securities Exchange Act of 1934, as amended.

Very truly yours,

 Jefferies LLC

As Representative of the several underwriters

[SIGNATURE PAGE FOLLOWS]

JEFFERIES LLC

By:

 /s/ Ashley Delp Walker

Name: Ashley Delp Walker

Title: Managing Director

 As representative of the several underwriters.

 [Signature Page to
Acceleration Request Letter]

CORRESP
1
filename1.htm

Company Acceleration Request

 GAMBLING.COM GROUP LIMITED

22 Grenville Street, St. Helier

Channel Island of Jersey JE4 8PX

 July 16,
2021

 VIA EDGAR

 United States Securities and
Exchange Commission

 Division of Corporation Finance

 100 F
Street, NE

 Washington, D.C. 20549

Re:
 REQUEST FOR ACCELERATION OF EFFECTIVENESS

Gambling.com Group Limited (CIK No. 0001839799)

Registration Statement on Form F-1 (File
No. 333-257403)

Ladies and Gentlemen:

 Pursuant to Rule 461 of
the rules and regulations promulgated under the Securities Act of 1933, as amended, the undersigned registrant hereby respectfully requests that the effective date for the Registration Statement referred to above be accelerated so that it will be
declared effective at 4:00 p.m. Eastern Daylight Time on Tuesday, July 20, 2021 or as soon thereafter as is practicable. In connection with the Registration Statement, the underwriters join in this request for acceleration by separate letter.

 Please contact Jessica Y. Chen at (212) 819-8503 or Charlotte Lan at (212) 819-8642 of White & Case LLP with any questions and please notify one or more of them when this request for acceleration has been granted.

[Remainder of Page Intentionally Blank]

 Sincerely,

 GAMBLING.COM GROUP LIMITED

By:

 /s/ Charles Gillespie

Name:

Charles Gillespie

Title:

Chief Executive Officer

CORRESP
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Response Letter

 July 14, 2021

VIA EDGAR

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, NE

Washington, D.C. 20549-3561

 Attn: Scott Anderegg

Gambling.com Group Ltd.

 Amendment No. 2 to
Registration Statement on Form F-1

 Filed July 12, 2021

File No. 333-257403

CIK No. 0001839799

 Dear Mr. Anderegg:

On behalf of our client, Gambling.com Group Ltd. (the “Company”), we hereby submit this letter in response to the comment (the “Comment”)
from the staff (the “Staff”) of the Securities and Exchange Commission (“Commission”) by letter dated July 14, 2021 with respect to the Company’s Amendment No. 2 to Registration Statement on Form F-1, as filed July 12, 2021.

 The Company has revised the Registration Statement in response to the Comment and is
filing concurrently with this letter the Amendment No. 3 to Registration Statement on Form F-1 (the “Registration Statement”), which reflects these revisions and updates and clarifies certain
other information.

 For the convenience of the Staff, we have retyped the Comment (displayed in bold) below, with the Company’s responses set forth
immediately below the Comment. All references to page numbers and captions (other than those in the Comment) correspond to pages and captions in the Registration Statement.

Recent Developments, page 9

 1. We note your
statement in your disclosure that your “actual results may differ materially from these estimates due...” If you choose to disclose preliminary results, you should be able to assert that the actual results are not expected to differ
materially from that reflected in the preliminary results. Accordingly, please remove this statement, as it implies that investors should not rely on the information presented.

Response: The Company respectfully acknowledges the Staff’s comment and has revised disclosures on page 9 of the Registration Statement.

* * *

 Securities and Exchange Commission

Gambling.com Group Limited

 July 14, 2021

 The Company welcomes any questions you may have and thank you for your attention to the Company’s
filings. The Company requests that should you require further clarification or additional information, please direct any questions or comments regarding the foregoing to John R. Vetterli at (212) 819-8816
or Jessica Y. Chen at (212) 819-8503.

 Sincerely,

/s/ White & Case LLP

 White & Case LLP

cc:
 Mr. Charles Gillespie, Chief Executive Officer, Gambling.com Group Ltd.

  Page
 2

United States securities and exchange commission logo
July 14, 2021
Charles Gillespie
Chief Executive Officer
Gambling.com Group Ltd
22 Grenville Street
St. Helier, Channel Islands of Jersey JE4 8PX
Re:Gambling.com Group Ltd
Amendment No. 2 to Form F-1
Filed July 12, 2021
File No. 333-257403
Dear Mr. Gillespie:
            We have reviewed your amended registration statement 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 letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to our comment, we may have additional comments.
Form S-1 Amendment No. 2 filed July 12, 2021
Recent Developments, page 9
1.We note your statement in your disclosure that your "actual results may differ materially
from these estimates due..." If you choose to disclose preliminary results, you should be
able to assert that the actual results are not expected to differ materially from that reflected
in the preliminary results.  Accordingly, please remove this statement, as it implies that
investors should not rely on the information presented.

 FirstName LastNameCharles Gillespie
 Comapany NameGambling.com Group Ltd
 July 14, 2021 Page 2
 FirstName LastName
Charles Gillespie
Gambling.com Group Ltd
July 14, 2021
Page 2
            You may contact Erin Jaskot at 202-551-3442 or Scott Anderegg at 202-551-3342 if you
have questions regarding our comment.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

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 WHITE & CASE

White & Case LLP

 1221 Avenue of the
Americas

 New York, NY 10020-1095

 T +1 212 819 8200

 whitecase.com

 June 25, 2021

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, NE

 Washington, D.C. 20549-3561

Attn: Scott Anderegg

 Gambling.com Group Ltd.

Amendment No. 1 to Draft Registration Statement on Form F-1

Confidentially Submitted May 25, 2021

 CIK
No. 0001839799

 Dear Mr. Anderegg:

 On behalf
of our client, Gambling.com Group Ltd. (the “Company”), we hereby submit this letter in response to the comments (the “Comments”) from the staff (the “Staff”) of the Securities and Exchange Commission
(“Commission”) by letter dated June 11, 2021 with respect to the Company’s Amendment No. 1 to Draft Registration Statement on Form F-1, as confidentially submitted to the Staff on
May 25, 2021.

 The Company has revised the Registration Statement in response to the Comments and is filing concurrently with this letter the
Registration Statement on Form F-1 (the “Registration Statement”), which reflects these revisions and updates and clarifies certain other information.

For the convenience of the Staff, we have retyped the Comments (displayed in bold) below, with the Company’s responses set forth immediately below the
Comments. All references to page numbers and captions (other than those in the Comments) correspond to pages and captions in the Registration Statement.

High-Quality Customer Base, page 4

 1. We note
your response to our prior comment four. Please further explain why you believe that online gambling traffic would transfer automatically to your other customers if you were to lose one of your significant online gambling operators. Please also tell
us whether your financial condition could be materially impacted if you lost a significant customer given the particular terms of your agreement with that customer or the revenue model used for payment under that agreement.

Response: The Company respectfully acknowledges the Staff’s comment. Similar to travel aggregator websites, such as Hotels.com, Expedia or Orbitz,
the Company’s customers are listed on its websites and apps where an end user may browse and

 WHITE & CASE

Securities and Exchange Commission

 Gambling.com Group Limited

 June 25, 2021

choose to engage with certain customers. If the Company or a customer terminated a contract, the Company would no longer promote that customer on the Company’s websites or apps.
Consequently, end users of the Company’s websites (i.e., online gamblers) would no longer see links to the former customer’s websites but would continue to see other customers featured on the Company’s websites and apps. For example,
if the Company were to stop working with a customer that appears in a top ten list, that customer would be replaced by any one of a long list of the Company’s other customers which qualify to appear in such list. End users would be unlikely to
notice any difference and would select an online gambling website from the list of ten regardless. (By analogy, a visitor to Hotels.com looking for accommodation in New York City is equally likely to book a hotel room regardless of the visibility
within the website of any single hotel in particular. On the other hand, if an end user were looking for a specific hotel or online gambling website, they would go directly to that site rather than first visiting a comparison-shopping portal such as
the Company’s websites.)

 As discussed below, one of the drivers of the Company’s revenue growth is increasing conversion rates with existing
customers rather than increasing the number of customers it features on its websites and apps. As disclosed on page 71 of the Registration Statement, in 2020, the Company’s reputation as an effective online gambling affiliate drew in over 450
inquiries from potential customers. However, the Company has only chosen to work with some 200 gambling operators as the Company is selective about only working with customers who have the highest expected conversion rates. As disclosed on page 14
of the Registration Statement, for the year ended December 31, 2020, the Company’s top ten customers accounted for 55% of the Company’s revenue and the Company’s largest customer accounted for 20% of the Company’s revenue.
These top customers contributed more revenue than the other customers because they were able to convert online gamblers into new depositing customers at a higher rate. The Company cannot guarantee that these top customers will always choose to use
the Company’s service. In the event the Company lost a top customer, although the Company is able to direct online gamblers (i.e., traffic) to the Company’s other existing customers, those customers might not be able to convert online
gamblers into new depositing customers as frequently as a top customer. While the loss of a top customer may cause a short-term negative impact on the Company’s revenue due to the potential that other customers may not be able to maintain
similarly high conversion rates as the top customer, the Company believes the risk of such impact being material to the Company’s overall financial performance to be low. Nevertheless, if the Company is unable to maintain and renew its
relationship with its largest customers then the Company’s business could be materially adversely affected.

 Further, the loss of any one customer,
even a top customer, will not interfere with the Company’s ability to attract end users to the Company’s websites and apps. The Company’s ability to attract end users depends, principally, on how Internet search engines rank the
Company’s websites for particular search queries, which in turn depends on the quality of the content of the Company’s websites, among other factors.

 Page 2

 WHITE & CASE

Securities and Exchange Commission

 Gambling.com Group Limited

 June 25, 2021

 Finally, the Company has comparable agreements with the vast majority of its customers. The key terms in the
agreement for its largest customer are not materially different from the key terms with the other customers. In the event that the Company loses its largest customer, the end users on the Company’s websites and apps would simply pick another
online gambling operator customer on the Company’s websites with whom the Company would maintain a similar commercial agreement.

 Competition,
page 74

 2. We note your response to our prior comment 9, however it is unclear why you believe that the online gaming operators you list here
are your competitors. We note that these online gaming operators generate revenue by providing gambling services to online gamblers, while you generate revenue through referral payments by directing customers to such online gaming operators. We
further note that many of these online gaming operators are your customers. Please advise and revise accordingly.

 Response: The Company
respectfully acknowledges the Staff’s comment and has revised disclosures on page 72 of the Registration Statement.

 * * *

The Company welcomes any questions you may have and thank you for your attention to the Company’s filings. The Company requests that should you
require further clarification or additional information, please direct any questions or comments regarding the foregoing to John R. Vetterli at (212) 819-8816 or Jessica Y. Chen at (212) 819-8503.

 Sincerely,

/s/ White & Case LLP

 White & Case LLP

cc:
 Mr. Charles Gillespie, Chief Executive Officer, Gambling.com Group Ltd.

 Page 3

United States securities and exchange commission logo
June 11, 2021
Charles Gillespie
Chief Executive Officer
Gambling.com Group Ltd
22 Grenville Street
St. Helier, Channel Islands of Jersey JE4 8PX
Re:Gambling.com Group Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted May 25, 2021
CIK No. 0001839799
Dear Mr. Gillespie:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
High-Quality Customer Base..., page 4
1.We note your response to our prior comment four.  Please further explain why you believe
that online gambling traffic would transfer automatically to your other customers if you
were to lose one of your significant online gambling operators.  Please also tell us whether
your financial condition could be materially impacted if you lost a significant customer
given the particular terms of your agreement with that customer or the revenue model
used for payment under that agreement.

 FirstName LastNameCharles Gillespie
 Comapany NameGambling.com Group Ltd
 June 11, 2021 Page 2
 FirstName LastName
Charles Gillespie
Gambling.com Group Ltd
June 11, 2021
Page 2
Compeition, page 74
2.We note your response to our prior comment 9, however it is unclear why you believe that
the online gaming operators you list here are your competitors.  We note that these online
gaming operators generate revenue by providing gambling services to online gamblers,
while you generate revenue through referral payments by directing customers to such
online gaming operators.  We further note that many of these online gaming operators are
your customers.  Please advise and revise accordingly.
            You may contact Tony Watson at 202-551-3318 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg at 202-551-3342 or Erin Jaskot at 202-551-3442 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

United States securities and exchange commission logo
April 22, 2021
Charles Gillespie
Chief Executive Officer
Gambling.com Group Ltd
22 Grenville Street
St. Helier, Channel Islands of Jersey JE4 8PX
Re:Gambling.com Group Ltd
Draft Registration Statement on Form F-1
Submitted March 25, 2021
CIK No. 0001839799
Dear Mr. Gillespie:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 submitted March 25, 2021
Overview, page 1
1.Please revise your discussion to disclose the basis upon which you have determined
that you are a leading provider of digital marketing in the online gambling industry.
Please see Form 20-F, Part I, Item 4. B. 7.

 FirstName LastNameCharles Gillespie
 Comapany NameGambling.com Group Ltd
 April 22, 2021 Page 2
 FirstName LastName
Charles Gillespie
Gambling.com Group Ltd
April 22, 2021
Page 2
Industry background, page 2
2.We note your reference to H2 Gambling Capital, Pareto Securities and Analytics
Insight for data on your industry. Please tell us whether you commissioned any of studies
or reports cited in your disclosure for use in the registration statement. If so, please
identify in your disclosure that you commissioned the study and file a consent(s) as an
exhibit to the registration statement. See Securities Act Rule 436.
3.Please provide support for your statement that you produce significantly more average
revenue per website than your peers.  Please also define who you are including as a peer
for this comparison.
High-Quality Customer Base Consisting of Major Online Gambling Operators., page 4
4.We note your statement that you have a robust client portfolio which includes most major
online gambling operators, as well as your risk factor on page 13 that you rely on a limited
number of customers for a significant portion of your revenue. To the extent that a loss of
a particular customer would have a material impact on your business, please identify such
customer. Please ensure that you file any material contracts with customers as exhibits to
your filing.  Please refer to Item 601(b)(10) of Regulation S-K.
Risk Factors
We rely on traffic to our websites to grow revenue..., page 12
5.Please quantify, to the extent practicable, the fluctuations you have experienced in search
rankings in the past so that investors have context for the degree of change that you have
experienced historically.  Please also reconcile your statement on page 4 that you are
adept at building websites that are ranked favorably by search engines such as Google
with your statement that factors affecting display and rankings of search results are not in
your direct control.  Please also provide support for your statement that Google and other
search engines prioritize high-quality content and that this is the most important factor in
SEO success.
An actual, alleged or perceived security incident, inadvertent disclosure or breach of sensitive
information, ..., page 15
6.Please tell us whether you have experienced any material disruptions, outages,
cyberattacks, attempts to breach your systems, or other similar incidents. If so, please
disclose such incidents, including the cost and impact of such incidents.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
36
7.You note that your revenue performance depends significantly on selecting the best
commercial model available to you for each of your customers.  Please tell us whether
trends or changes in the commercial models that you have with your customers in

 FirstName LastNameCharles Gillespie
 Comapany NameGambling.com Group Ltd
 April 22, 2021 Page 3
 FirstName LastName
Charles Gillespie
Gambling.com Group Ltd
April 22, 2021
Page 3
comparable periods has a material impact on your financial performance.  If so, please
revise your disclosure to explain the trends or changes and how they have impacted your
results of operations.
Our Sales Process and Customers, page 66
8.Please disclose the number of customers that you have had in prior fiscal years versus the
number of customers that you have today.  Please also disclose any trends that you believe
have impacted the number of your customers from period-to-period.
Competition, page 67
9.Please tell us why you believe that online gambling operations such as DraftKings Inc. or
Rush Street Interactive, Inc. are comparable companies.
Principal Shareholders, page 78
10.Please identify the natural person or persons with investment and voting control over the
shares held by Edison Partners IX, LP.
Certain Relationships and Related Party Transactions
Agreements with Directors and Officers, page 79
11.Please file the employment agreements with your executive officers and directors as
exhibits to the registration statement.
            You may contact Tony Watson at 202-551-3318 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg at 202-551-3342 or Erin Jaskot at 202-551-3442 if you have any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services