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                              December 13, 2022

       Mark Locke
       Chief Executive Officer and Director
       Genius Sports Ltd
       9th Floor, 10 Bloomsbury Way
       London, WC1A 2SL

                                                        Re: Genius Sports Ltd
                                                            Registration 
Statement on Form F-4
                                                            Filed November 18, 
2022
                                                            File No. 333-268457

       Dear Mark Locke:

              We have limited our review of your registration statement to 
those issues we have
       addressed in our 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 this comment, we may have additional comments.

       Registration Statement on Form F-4 Filed November 18, 2022

       General

   1.                                                   Please ensure that this 
registration statement is updated as necessary in accordance with
                                                        comments you receive 
regarding, and changes you make to, your Schedule TO-I (File
                                                        No. 005-93523).
               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.

              Refer to Rules 460 and 461 regarding requests for acceleration. 
Please allow adequate
       time for us to review any amendment prior to the requested effective 
date of the registration
       statement.
 Mark Locke
Genius Sports Ltd
December 13, 2022
Page 2

       Please contact Taylor Beech at 202-551-4515 or Lilyanna Peyser at 
202-551-3222 with
any questions.



                                                         Sincerely,
FirstName LastNameMark Locke
                                                         Division of 
Corporation Finance
Comapany NameGenius Sports Ltd
                                                         Office of Trade & 
Services
December 13, 2022 Page 2
cc:        Ross Leff, Esq.
FirstName LastName