United States securities and exchange commission logo May 24, 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 File No. 001-40504 Dear Sagi Niri: 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 cc: Amy Rothstein