United States securities and exchange commission logo

                              March 18, 2021

       Alexander Gersh
       Chief Financial Officer
       Sportradar Holding AG
       150 South 5th St., Suite 400
       Minneapolis, MN 55402

                                                        Re: Sportradar Holding
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted February
19, 2021
                                                            CIK No. 0001836470

       Dear Mr. Gersh:

              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

             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

       Draft Registration Statement on Form F-1 Submitted February 19, 2021

       Prospectus Summary, page 1

   1.                                                   We note your statements
in the second paragraph of this section. Provide support for your
                                                        assertions that your
"platform is the backbone to the sports betting industry, and the scale
                                                        of [your] data and
content operation is unparalleled."
   2.                                                   We note your references
to "top-tier investors" such as CPP Investments and Technology
                                                        Crossover Ventures and
to "notable sports industry individuals" such as Ted Leonsis,
                                                        Mark Cuban and Michael
Jordan as investors. However, we note that none of these
                                                        entities nor prominent
individuals are listed in your beneficial ownership table. To
                                                        provide proper context
to their mention, disclose their share ownership in the company.
 Alexander Gersh
FirstName  LastNameAlexander Gersh
Sportradar Holding AG
March      NameSportradar Holding AG
       18, 2021
March2 18, 2021 Page 2
FirstName LastName
Summary Consolidated Financial and Other Data, page 17

3.       Please revise here to disclose the comparable IFRS measures for
adjusted EBITDA
         margin    and    cash flow conversion    with equal or greater
prominence wherever you
         discuss these measures. Refer to Item 10(e)(1)(i)(A) of Regulation S-K
and Question
         102.10 of the non-GAAP Compliance and Disclosure Interpretations
         Also, remove the measure of total segment adjusted EBITDA on page 85
or revise to
         reconcile this non-GAAP measure.
4.       Please explain further the adjustment for amortization of sports
rights to your non-GAAP
         measure of adjusted EBITDA. Specifically address why you have excluded
a significant
         portion of your amortization expense from your calculation and explain
what your
         measure of adjusted EBITDA as presented is attempting to convey. Also,
revise to clarify
         how this measure as presented provides useful information to
investors. Refer to Item
         10(e)(1)(i)(c) of Regulation S-K.
5.       Please address the following as it relates to your non-GAAP measure of
free cash flow:
             You refer to this measure as both a performance and liquidity
measure in footnote
             (4). Tell us why you believe this measure is a performance measure
or revise to
             appropriately identify this as a liquidity measure only. Refer to
Question 102.07 of
             the non-GAAP C&DIs.
             Your adjustment for acquisition of intangible assets excludes
certain intangible assets
             required to further support an acquired business. Tell us the
amount of acquired
             intangible assets that have been excluded from this measure. Also,
explain further
             what the excluded amount represents and how you determined that
such exclusion
             appropriately reflects your measure of free cash flow.
             Tell us how the adjustment for interest paid on bank debt complies
with the
             prohibition in Item 10(e)(ii)(A) of Regulation S-K regarding the
exclusion of charges
             that required, or will require, cash settlement from a non-GAAP
liquidity measure.
             Considering such measure contains adjustments other than capital
             please revise to label the measure as    adjusted free cash flow"
so it is not confused
             with free cash flow as typically calculated. Refer to Question
102.07 of the Non-
             GAAP C&DIs.
Risk Factors
Financial and Capital Risks
We have identified material weaknesses in our internal control, page 48

6.       Please revise to clarify what plans, if any, have been fully
implemented and what remains
         to be completed in your remediation efforts. Also, disclose how long
you estimate it will
         take to complete your remediation plan and discuss any associated
material costs that you
         have incurred or expect to incur.
 Alexander Gersh
FirstName  LastNameAlexander Gersh
Sportradar Holding AG
March      NameSportradar Holding AG
       18, 2021
March3 18, 2021 Page 3
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Our Customers and Business Model, page 77

7.       You disclose that you serve over 1,600 customers. Please revise to
provide the actual
         number of customers for each period presented.
Key Performance Indicators, page 82

8.       Please clarify whether the top 200 customers included in your
calculation of dollar-based
         net retention rate includes customers with both subscription and
revenue share
         arrangements. If so, explain further how this measure demonstrates
your ability to expand
         the scope of services for customers whose contracts are based on
revenue share schemes.
         To the extent this metric includes only subscription customers, please
revise to indicate as
Management's Discussion and Analysis of Financial Condition and Results of
Segments, page 85

9.       Please disclose the geographic regions included in your RoW Betting
segment. Also,
         clarify whether all revenues included in RoW AV are generated from
customers outside
         the U.S.
Business, page 95

10.      You state that you are reliant on licenses to certain data and other
intellectual property
         rights, including strategic partnerships with some major sports
leagues. Please include a
         more comprehensive discussion of your sports league partnership
agreements here. For
         example, describe the typical terms for such arrangements; disclose
when any key
         contracts expire; and clarify whether such agreements have renewal
rights. Also, revise
         your risk factor discussion on page 51 to disclose the amount of
intangible assets related
         specifically to your sports league license rights.
Consolidated Financial Statements
Consolidated Statement of Profit or Loss and Other Comprehensive Income, page

11.      Please tell us whether your consolidated statement of profit or loss
is intended to present
         your expenses by function or nature. In this regard, you include
certain items that are
         expenses by nature (e.g. cost of purchased services) and other items
that are expenses by
         function (e.g. depreciation and amortization). Refer to paragraphs 99
- 104 of IAS 1. In
         addition, explain further your inclusion of capitalized
internally-developed software costs
         on the face of your statement of profit or loss.
12.      We note that your cost of purchased services does not include
amortization expense
         related to your sports rights. Please revise your cost of purchased
services line item to
         clearly indicate that it is exclusive of depreciation and amortization
and separately
         disclose the amount of such costs that have been excluded. Refer to
SAB Topic 11.B.
 Alexander Gersh
FirstName  LastNameAlexander Gersh
Sportradar Holding AG
March      NameSportradar Holding AG
       18, 2021
March4 18, 2021 Page 4
FirstName LastName
Betting data/Betting entertainment tools, page F-25

13.      You disclose that in some of your Sports Betting contracts, the
customer is not obliged to
         pay you until the customer has generated    income.    Please explain
in further detail what
         income measure is used to determine the customer   s payment
obligation. Similarly, you
         state that for managed trading services the company receives a share
of revenue or loss
         made by the client on the bet. Please clarify what is meant by revenue
or loss and how
         this compares to your reference on page 78 to receiving a fixed
percentage of gross
         gaming revenue or net gaming revenue.
14.      Please explain further your disclosures, which indicate that variable
consideration is
         initially constrained and therefore, revenue is recognized based on
actual customer sale
         performance. In this regard, clarify whether you have fully
constrained the variable
         consideration if so, tell us how you considered the guidance in
paragraphs 56-57 of IFRS
Notes to Consolidated Financial Statements
Note 5. Revenue from contracts with customers, page F-25

15.      We note that for your Betting Data/Betting Entertainment and Betting
         services revenue is recognized over the term of the contract for the
initial agreed upon
         amount, which includes agreed upon levels of data and/or services and
any additional
         amounts in excess of the contractually stated amounts is recognized as
incurred. Please
         describe further the terms of these arrangements. Tell us whether the
data and service
         level commitments cover the entire term of the arrangement or certain
incremental periods
         within the contract term (e.g. monthly, quarterly, etc.). Tell us how
often customers
         exceed these amounts and provide the amount of revenue earned from
single match
         bookings and additional AV services for each period presented. Lastly,
tell us how you
         determined that recognizing such arrangements over the contract term
depicts the best
         measure of progress to completion. Refer to paragraphs 39 - 45 of IFRS
16.      Please explain in detail how you determined that the single match
bookings are capable of
         being distinct from the stand ready service. Refer to paragraph 27 of
IFRS 15.
Note 11. Intangible assets and goodwill
11.1 Impairment test, page F-33

17.      Please further explain and revise your disclosures as necessary to
clarify the facts and
         circumstances that lead to an impairment of your NBA and NFL license
rights in fiscal
         2019. Specifically address what is meant by your reference to slower
opening of relevant
         market and clarify how each market and segment were impacted. Similar
         should be provided for any license right impairment charges recorded
during fiscal
         2020. Refer to paragraph 130(a) of IAS 36. Lastly, tell us, and revise
to clarify, where
         these agreements are reflected in the breakdown of estimated useful
lives on page F-15.
 Alexander Gersh
Sportradar Holding AG
March 18, 2021
Page 5
Note 26. Related party transactions, page F-51

18.   You state that no compensation expense was recognized for the 311,503
share awards
      granted under the management participation plan (MPP) during fiscal 2019
since such
      awards were issued at fair value. Please explain further how you
determined that such
      awards were not compensatory. Provide the specific guidance in IFRS 2
that you relied
      upon and specifically address your consideration of IFRS 2, paragraph
BC79. In addition,
      tell us whether the accounting will be impacted when these awards are
exchanged for
      Class A ordinary shares upon effectiveness of the offering and if so,
19.   Please provide us with a breakdown of awards granted under both your
      Participation Program and Phantom Option Plan during fiscal 2020 and to
date in 2021.
      Tell us how you valued such awards and how you determined the fair value
      any ordinary shares underlying such awards at the date of each grant. To
the extent there
      were significant fluctuations in the fair values from period-to-period,
describe for us the
      factors that contributed to these fluctuations, including any intervening
events within the
      company or changes in your valuation assumptions or methodology used to
value such
      award. Also, describe further how these awards will be impacted upon
consummation of
      the offering and the amount of compensation expense, if any, that will be
recorded upon

20.   We note that you cite estimates and statistics throughout the prospectus.
      Please identify the source publications and reports for these estimates
and statistics.
21.   Please supplementally provide us with copies of all written
communications, as defined
      in Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your
      behalf, present to potential investors in reliance on Section 5(d) of the
Securities Act,
      whether or not they retain copies of the communications.
        You may contact David Edgar, Staff Accountant, at (202) 551-3459 or
Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions regarding
comments on the
financial statements and related matters. Please contact Michael C. Foland,
Attorney-Advisor, at
(202) 551-6711 or Larry Spirgel, at (202) 551-3815 with any other questions.

FirstName LastNameAlexander Gersh
                                                             Division of
Corporation Finance
Comapany NameSportradar Holding AG
                                                             Office of
March 18, 2021 Page 5
cc:       John Slater
FirstName LastName