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United States securities and exchange commission logo
May 16, 2023
Gerard Griffin
Chief Financial Officer
Sportradar Group AG
Feldistrasse 2
CH-9000 St. Gallen, Switzerland
Re: Sportradar Group AG
Form 20-F for the
Year Ended December 31, 2022
Filed on March 15,
2023
Form 6-K Submitted
on May 10, 2023
Dear Gerard Griffin:
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.
From 20-F for the Year Ended December 31, 2022
Item 5. Operating and Financial Review and Prospects
Key Financial and Operational Performance Indicators, page 78
1. We note that you
highlight adjusted free cash flow as a key performance indicator without
also highlighting the
comparable IFRS measure in this chart. Please revise to include the
comparable IFRS measure
with equal or greater prominence. Refer to Question 102.10 of
the non-GAAP C&DIs.
Non-IFRS Financial Measures and Operating Metrics, page 79
2. Please explain further
your adjustment for foreign currency gains on cash equivalents
included in your
reconciliation of adjusted free cash flows. Tell us why the amounts for
fiscal 2021 and 2020
differ from the amounts disclosed in the statement of cash flows. In
addition, clarify what
this measure, as adjusted for foreign currency gains, is attempting to
convey, how management
uses such measure, and how it is useful to investors.
Gerard Griffin
Sportradar Group AG
May 16, 2023
Page 2
3. Also, tell us whether the acquisition of intangible assets line item
included in your
adjusted free cash flow reconciliation excludes intangibles assets
required to support an
acquired business for any periods presented. If so, tell us what
acquisition such exclusion
relates to, the reasons such assets are excluded in calculating adjusted
free cash
flow and include an explanation in a footnote to this reconciliation.
Alternatively, revise
to remove this parenthetical reference from your reconciliation of
adjusted free cash flow.
Item 18. Financial Statements
Notes to Consolidated Financial Statements
Note 24. Other Liabilities, page F-56
4. We note that as part of the settlement agreement with Genius Sports, the
Group purchased
a sublicense through 2024 for a delayed feed to be marketed as the
Official FDC
Secondary Feed. Please tell us whether the cost of such sublicense is
included in the
19.0M settlement payment to Genius Sports. If so, tell us the portion
of such settlement
applicable to the sublicense. Lastly, tell us how you determined to
account for the
sublicense as operating expenses upon settlement and provide the
specific accounting
guidance applied.
Form 6-K Submitted on May 10, 2023
Exhibit 99.1 , page 1
5. You present adjusted EBITDA margin and cash flow conversion without
presenting the
comparable IFRS measures of profit for the period as a percentage of
revenue or net cash
from operating activities as a percentage of profit for the year. Please
revise. Refer to
Item 100(a)(1) of Regulation G.
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 David Edgar, Senior Staff Accountant, at (202) 551-3459
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 with any questions.
Sincerely,
FirstName LastNameGerard Griffin
Division of
Corporation Finance
Comapany NameSportradar Group AG
Office of
Technology
May 16, 2023 Page 2
cc: Jason Barr
FirstName LastName