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                             June 8, 2023

       Elias Mark
       Chief Financial Officer
       Gambling.com Group Ltd
       22 Grenville Street
       St. Helier, Channel Island of Jersey JE4 8PX

                                                        Re: Gambling.com Group
Ltd
                                                            Form 20-F for
Fiscal Year Ended December 31, 2022
                                                            Filed March 23,
2023
                                                            File No. 001-40634

       Dear Elias Mark:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 20-F for Fiscal Year Ended December 31, 2022

       Business Overview, page 32

   1.                                                   We note your disclosure
of Adjusted EBITDA margin. Please revise to provide disclosure
                                                        of the most directly
comparable IFRS measure with equal or greater prominence. Refer to
                                                        Item 10(e)(1)(i)(A) of
Regulation S-K.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 45

   2.                                                   We note your disclosure
on page F-15 that revenue-share fees are a percentage of the net
                                                        gaming revenues an
operator generates over the lifetime of the referred player. It is not
                                                        clear from your
disclosure the extent to which revenue recognized in a particular period
                                                        results from referrals
in the current year or referrals from prior years. Please consider
                                                        whether quantification
of revenue from new and pre-existing referrals would provide
                                                        meaningful information
to investors about the duration of your income streams and the
 Elias Mark
Gambling.com Group Ltd
June 8, 2023
Page 2
         extent to which your business relies on new referrals for the
maintenance and growth of
         revenue levels.
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-15

3.       You disclose that negative revenue share amounts usually do not carry
over into
         subsequent months. Please describe for us the nature of negative
revenue share amounts.
18. Revenue, page F-41

4.       We note that you earn performance marketing fees in the form of
ongoing revenue-shares,
         one-time fees, and a hybrid of these two forms. Please tell us your
consideration of
         disaggregating performance marketing fees along these lines, given the
differences in the
         nature and timing of these forms of fees.
Note 19. Operating Expenses
Sales and Marketing Expenses, page F-43

5.       Please explain your consideration of classifying amortization of
certain intangible assets
         as cost of sales instead of 'Sales and marketing expenses.' In this
regard, we note
         you attribute the increase in amortization expense primarily to the
acquisition of
         RotoWire.com and BonusFinder.com in 2022, and their related domain
names, apps, and
         customer contracts on page 49, which appears related to cost of sales.
Refer to SAB
         Topic 11B.
6.       Please disclose the nature of external content costs. Also, explain to
us your consideration
         of classification of external content as a component of cost of sales
as these costs appear
         integrally related to your revenue generating activities, particularly
for RotoWire and
         BonusFinder acquired in 2022. In this regard, we note that you earn
revenue from
         subscriptions.
       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.

       You may contact Robert Shapiro at 202-551-3273 or Lyn Shenk at
202-551-3380 with
any questions.



FirstName LastNameElias Mark                                   Sincerely,
Comapany NameGambling.com Group Ltd
                                                               Division of
Corporation Finance
June 8, 2023 Page 2
FirstName LastName                                             Office of Trade
& Services