United States securities and exchange commission logo June 9, 2022 Dermot Smurfit Chief Executive Officer GAN Limited 400 Spectrum Center Drive, Suite 1900 Irvine, CA 92618 Re: GAN Limited Form 10-K for the Year Ended December 31, 2021 Filed April 15, 2022 File No. 001-39274 Dear Mr. Smurfit: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Technology