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April 21, 2023
Sagi Niri
Chief Financial Officer
Tremor International Ltd.
82 Yigal Alon Street
Tel Aviv, Israel, 6789124
Re: Tremor
International Ltd.
Form 20-F for the
year ended December 31, 2022
Filed March 7, 2023
Form 6-K Submitted
March 7, 2023
File No. 001-40504
Dear Sagi Niri:
We have reviewed your April 19, 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
additional comments.
Unless we note otherwise, our references to prior comments are to
comments in our March 29,
2023 letter.
Form 6-K Submitted March 7, 2023
General
1. Your response to prior
comment 8 indicates that CTV spend and PMP spend
represent sales in the
Connected TV and private marketplace markets; however, you also
note that they are
non-GAAP measures that are derived from Contribution ex-TAC.
As Contribution ex-TAC
is a profit measure that is derived from GAAP gross profit it is
unclear how "spend", a
sales measure, is derived from Contribution ex-TAC. Please
advise. Also, as
previously requested, please provide us with your proposed disclosures.
Sagi Niri
FirstName LastNameSagi
Tremor International Ltd. Niri
Comapany
April NameTremor International Ltd.
21, 2023
April 221, 2023 Page 2
Page
FirstName LastName
You may contact Christine Dietz, Senior Staff Accountant, at (202)
551-3408 if you have
questions.
Sincerely,
Division of
Corporation Finance
Office of Technology
cc: Amy Rothstein