May 29, 2019

Grant Johnson
Chief Executive Officer
Esports Entertainment Group, Inc.
170 Pater House, Psaila Street
Birkirkara, Malta, BKR 9077

       Re: Esports Entertainment Group, Inc.
           Registration Statement on Form S-1
           Filed January 3, 2015

Dear Mr. Johnson:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. In some of our comments, 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 comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-1 filed May 2, 2019

Cover Page

1.     Please revise the disclosure that you "are offering up to
_________units" in light of this
       being a firm commitment offering.
Summary, page 1

2.     We note your statement that "At the current time, under our existing
Curacao license, we
       are able to accept wagers from residents of over 149 jurisdictions
including Canada,
       Japan, Germany and South Africa." Please disclose in the summary section
that bets may
       not be placed on your website by residents of the United States. In
addition, we note the
       disclosure on page 49 that bets may not be placed by residents of the
European Union
       member countries. Please clarify whether German residents may place bets
on your
       website.
 Grant Johnson
FirstName LastNameGrant Johnson
Esports Entertainment Group, Inc.
Comapany NameEsports Entertainment Group, Inc.
May 29, 2019
May 29, 2019 Page 2
Page 2
FirstName LastName
3.       Please revise the sentence beginning with "According to Statista..."
to state, if true, that
         the amount wagered on sports betting in 2015 was $315 million rather
than $3.15 million.
Business, page 46

4.       In your Growth Strategy section please revise to further explain the
difference
         between Online Esports Tournament Play and Live Esports Tournament
Play.
5.       We note your discussion of the U.S. Supreme Court striking down the
Professional and
         Amateur Sports Protection Act, a 1992 law that barred state-authorized
sports gambling
         with some exceptions. If material, please discuss the applicability of
the Unlawful
         Internet Gambling Enforcement Act of 2006 to your business.
Underwriting, page 68

6.       Please revise the statement on page 68 that "[i]f all of the units
offered by [you] are not
         sold at the public offering price, the underwriters may change the
offering price and other
         selling terms by means of a supplement to this prospectus" to clarify
that, if required, you
         will file a post effective amendment.
Exhibits

7.       Please file your 2014 and 2017 consulting agreements as exhibits or
tell us why this is not
         required pursuant to Item 601(b)(10) of Regulation S-K. Additionally
tell us why you are
         not required to file your agreements with Money Matrix, Partner
Matrix, and SportsRadar.
General

8.       Please revise to provide all disclosure that may not be omitted
pursuant to Rule 430A. For
         example, but without limitation, we note that you have not disclosed
the number of units
         you are offering, the number of units or warrants to cover over
allotments, and exercise
         price information for the warrants. Additionally please provide
disclosure in the Use of
         Proceeds, Capitalization, and Dilution sections using an estimated
offering price.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Grant Johnson
Esports Entertainment Group, Inc.
May 29, 2019
Page 3

       You may contact Dana Brown at 202-551-3859 or Anne Parker, Assistant
Director, at 202-551-3611 if you have questions .



FirstName LastNameGrant Johnson                        Sincerely,
Comapany NameEsports Entertainment Group, Inc.
                                                       Division of Corporation
Finance
May 29, 2019 Page 3                                    Office of Transportation
and Leisure
FirstName LastName