November 26,
2019

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

       Re: Esports Entertainment Group, Inc.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed October 30, 2019
           File No. 333-231167

Dear Mr. Johnson:

      We have reviewed your amended registration statement and have the
following
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. Unless
we note
otherwise, our references to prior comments are to comments in our May 29, 2019
letter.

Amended Form S-1 filed October 30, 2019

Business, page 44

1.     We note your response to our prior comment 5. Please tell us why your
discussion uses
       the state law doctrines of the Dominant Factor Test and Material Element
Test in your
       discussion of the UIEGA, which is a federal statute. If courts have used
these state law
       tests to interpret this federal statute please advise. If these tests
are not applicable to the
       interpretation of the UIEGA please revise your discussion.
Exhibits

2.     We note your response to our prior comment 7. Your response in regard to
your 2014 and
       2017 consulting agreements was unclear. Please file these agreements as
exhibits or tell
 Grant Johnson
Esports Entertainment Group, Inc.
November 26, 2019
Page 2
         us why this is not required pursuant to Item 601(b)(10) of Regulation
S-K.
General

3.       We note your response to our prior comment 8. Prior to circulating a
preliminary
         prospectus, please revise to disclose the number of units or warrants
to cover over
         allotments. Also revise the first sentence of your Use of Proceeds
discussion to disclose
         the estimated net offering proceeds. Additionally provide the
remainder of the
         information in your Dilution table based on estimates and available
information.
       Please contact John Dana Brown at 202-551-3859 or Justin Dobbie at
202-551-3469 with
any questions.



FirstName LastNameGrant Johnson                               Sincerely,
Comapany NameEsports Entertainment Group, Inc.
                                                              Division of
Corporation Finance
November 26, 2019 Page 2                                      Office of Trade &
Services
FirstName LastName