NeoGames S.A. 

5, rue de Bonnevoie 

L-1260 Luxembourg 

Grand Duchy of Luxembourg


November 16, 2020




United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E. 

Washington, D.C. 20549-6010


Attention: Scott Anderegg
  Jennifer López
  Amy Geddes
  Linda Cvrkel


Re:Neogames S.A.
  Registration Statement on Form F-1 (File No. 333-249683)


Ladies and Gentlemen:


In accordance with Rule 461 of under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form F-1, as amended (File No. 333-249683) (the “Registration Statement”) of NeoGames S.A. (the “Company”). We respectfully request that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on Wednesday, November 18, 2020, or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Gilad Zohari at (212) 906-4667.


We understand that the staff of the Securities and Exchange Commission will consider this request as confirmation by the Company that it is aware of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Gilad Zohari of Latham & Watkins LLP at the number set forth above.


Thank you for your assistance in this matter.


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November 16, 2020

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  Very truly yours,
  NeoGames S.A.
  By: /s/ Moti Malul
    Name: Moti Malul
    Title: Chief Executive Officer


cc: (via email)
  Raviv Adler, Neogames S.A.
  Josh Kiernan, Esq., Latham & Watkins LLP
  Nathan Ajiashvili, Esq., Latham & Watkins LLP
  Gilad Zohari, Esq., Latham & Watkins LLP
  Gil White, Esq., Herzog Fox & Neeman
  Ron Ben-Menachem, Esq., Herzog Fox & Neeman
  David J. Goldschmidt, Esq., Skadden, Arps, Slate, Meagher & Flom LLP
  Yossi Vebman, Esq., Skadden, Arps, Slate, Meagher & Flom LLP