United States securities and exchange commission logo May 15, 2023 Dermot Smurfit Chief Executive Officer GAN Ltd 400 Spectrum Center Drive, Suite 1900, Irvine, CA 92618 Re: GAN Ltd Registration Statement on Form S-1 Filed May 8, 2023 File No. 333-271734 Dear Dermot Smurfit: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Aliya Ishmukhamedova, Staff Attorney, at 202-551-7519 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Jeffrey H. Kuras