TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo November 30, 2023 John Hanson Chief Financial Officer Turtle Beach Corp 44 South Broadway 4th Floor White Plains, NY 10601 Re: Turtle Beach Corp Form 10-K for Fiscal Year Ended December 31, 2022 Response Dated October 6, 2023 File No. 001-35465 Dear John Hanson: We have reviewed your October 6, 2023 response to our comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our September 20, 2023 letter. Form 10-K for Fiscal Year Ended December 31, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Key Performance Indicators and Non-GAAP Measures, page 27 1. We have reviewed your response to prior comments 1 and 2. Based on your responses, the adjustments to your non-GAAP financial measures for employee and executive retention costs and for inventory and component related reserves appear to be normal operating expenses necessary to operate your business. As such, these adjustments are inconsistent with Question 100.01 of the Non-GAAP Financial Measures Compliance & Disclosure Interpretations. Please revise your non-GAAP measures in future filings to remove these adjustments. John Hanson FirstName LastNameJohn Hanson Turtle Beach Corp Comapany 30, November NameTurtle 2023 Beach Corp November Page 2 30, 2023 Page 2 FirstName LastName Please contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing