United States securities and exchange commission logo

                               November 13, 2020

       Moti Malul
       Chief Executive Officer
       NeoGames S.A.
       5, rue de Bonnevoie
       L-1260 Luxembourg
       Grand Duchy of Luxembourg

                                                        Re: NeoGames S.A.
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed November 9,
                                                            File No. 333-249683
                                                            Amendment No. 2 to
Registration Statement on Form F-1
                                                            Filed November 12,
                                                            File No. 333-249683

       Dear Mr. Malul:

              We have reviewed your amended registration statement and have the
       comment. In our comment, we may ask you to provide us with information
so we may better
       understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your

              After reviewing any amendment to your registration statement and
the information you
       provide in response to our comment, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
November 4, 2020 letter.

       Amendment No. 2 to Form F-1 Filed November 12, 2020


   1.                                                   Please revise your
disclosure to describe Article 24 of your Amended and Restated
                                                        Articles of
Association, discuss any risks or other impacts of such provision on your
                                                        investors (including,
for example, increased costs to bring a claim, the dicouragement of
                                                        claims, and the
limitation on investors' ability to bring claims in a judicial forum they find
                                                        favorable), and address
any uncertainty as to whether a court would enforce the provision
 Moti Malul
NeoGames S.A.
November 13, 2020
Page 2
         (for example, because it limits the concurrent jurisdiciton provided
by Section 22 of the
         Securities Act).
       Please contact Scott Anderegg at 202-551-3342 or Lilyanna Peyser at
202-551-3222 with
any other questions.

FirstName LastNameMoti Malul                                   Sincerely,
Comapany NameNeoGames S.A.
                                                               Division of
Corporation Finance
November 13, 2020 Page 2                                       Office of Trade
& Services
FirstName LastName