December 17, 2024

Yves Le Pendeven
Chief Financial Officer
Funko, Inc.
2802 Wetmore Avenue
Everett, WA 98201

        Re: Funko, Inc.
            Form 10-K for the Year Ended December 31, 2023
            Filed March 7, 2024
            Form 8-K Filed November 7, 2024
            File No. 001-38274
Dear Yves Le Pendeven:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       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.

Form 10-K for the Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Non-GAAP Financial Measures, page 70

1.     In regard to your presentation of non-GAAP financial measures, please
address the
       following items.
           We note adjustment (4) related to Acquisition transaction costs and
other
           expenses and adjustment (5) related to Certain severance, relocation
and related
           costs. More fully disclose and discuss the specific nature and
amounts of the types
           of costs included in each adjustment for the years ended December
31, 2023 and
           2022 and the nine months ended September 30, 2024 and 2023. Please
also
           explain to us how you determined that the adjustments related to
each type of cost
           is appropriate based on the guidance in Question 100.01 of the SEC
s Non-GAAP
           Financial Measures Compliance & Disclosure Interpretations.
 December 17, 2024
Page 2

             We note the adjustments related to (8) one-time cloud based
computing
           arrangement abandonment, (9) one-time disposal costs for finished
goods held at
           offshore factories, (10) one-time disposal costs for unfinished
goods held at
           offshore factories, and (11) inventory write-down. It appears to us
that these items
           represent normal operating expenses related to your business and
should not be
           eliminated from non-GAAP financial measures. Please revise future
disclosures to
           not exclude these adjustments from your Non-GAAP performance
measures or
           explain why you believe these adjustments are appropriate. Refer to
Question
           100.01 of the SEC's Non-GAAP Financial Measures Compliance and
Disclosure
           Interpretations.

Form 8-K Filed November 7, 2024
Use of Non-GAAP Financial Measures

2.     We note your disclosure that your senior secured credit facilities use
adjusted
       EBITDA to measure your compliance with covenants, such as senior
leverage ratio.
       Please clarify whether you are using adjusted EBITDA as both a
performance and
       liquidity measure. If so, please enhance your disclosure to also
reconcile adjusted
       EBITDA to the most directly comparable GAAP liquidity measure, cash
provided by
       operating activities, and separately discuss the limitations of your
non-GAAP
       measures as both performance and liquidity measures.
        In closing, 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.

       Please contact Jeffrey Gordon at 202-551-3866 or Ernest Greene at
202-551-3733
with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing