United States securities and exchange commission logo

                             June 22, 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,
                                                            Form 6-K Submitted
on May 10, 2023

       Dear Gerard Griffin:

               We have reviewed your May 30, 2023 response to our comment
letter 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 comment 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
       comment applies to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to this comment, we may have
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       May 16, 2023 letter.

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

       Non-IFRS Financial Measures and Operating Metrics, page 79

   1.                                                   We note your response
to prior comment 2 and that the adjustment    foreign currency
                                                        gains on cash
equivalents    represents the exchange rate movement on certain cash
specifically, your investments in U.S. Dollar money market funds. While the
                                                        effect of exchange rate
fluctuation on cash held in foreign currencies affects the cash
                                                        balance during a
period, it does not represent cash receipts or payments. The impact of
                                                        exchange rate
fluctuation does not give rise to cash flows, therefore, such adjustment does
                                                        not appear to be
appropriate in determining a non-GAAP measure of cash flows. Please
                                                        refer to paragraph 28
of IAS 7 and revise accordingly.
 Gerard Griffin
FirstName  LastNameGerard Griffin
Sportradar Group AG
June       NameSportradar Group AG
     22, 2023
June 22,
Page 2 2023 Page 2
FirstName LastName
       You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have any questions.


                                                         Division of
Corporation Finance
                                                         Office of Technology
cc:      Jason Barr