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United States securities and exchange commission logo





                     October 5, 2021

       Ann Hand
       Chief Executive Officer
       Super League Gaming, Inc.
       2912 Colorado Ave., Suite #203
       Santa Monica, California 90404

                                                        Re: Super League
Gaming, Inc.
                                                            Form 10-K For the
Fiscal Year Ended December 31, 2020
                                                            Filed March 19,
2021
                                                            File No. 001-38819

       Dear Ms. Hand:

              We have reviewed your September 21, 2021 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
       September 1, 2021 letter.
 Ann Hand
FirstName  LastNameAnn
Super League  Gaming, Inc.Hand
Comapany
October    NameSuper League Gaming, Inc.
        5, 2021
October
Page 2 5, 2021 Page 2
FirstName LastName
Form 10-K for the Fiscal Year Ended December 31, 2020

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

1.       We note your response to prior comment 2. It appears that the
information provided in the
         response on costs included in cost of revenues is the same description
provided on page F-
         9 for costs included in technology platform and infrastructure costs.
Please advise.
         Additionally, we note that you are a leading gaming community and
content platform
         powered by patented, proprietary technology systems. Based on the
nature of your
         operations, it appears that technology platform and infrastructure
costs are essential to
         your business and without them, you would not be able to generate
revenues. We
         note, however, that these costs appear to be significant in comparison
to the amounts
         included in cost of revenues. Please tell us your basis for
determining whether a cost is
         classified as cost of revenues or technology platform and
infrastructure costs.
        You may contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at
202-551-
3307 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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