May 6, 2019

Russell Nickel
Chief Financial Officer
Funko, Inc.
2802 Wetmore Avenue
Everett, Washington 98201

       Re: Funko, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed March 6, 2019
           File No. 001-38274

Dear Mr. Nickel:

       We have reviewed your filing 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 10-K for the Fiscal Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Financial Measures, page 71

1.    The presentation of "adjusted pro forma net income" on page 72 does not
appear to be
      presented in accordance with the pro forma requirements of Article 11 of
Regulation S-X.
      Accordingly, please remove "pro forma" from the description of this
measure.
Liquidity and Capital Resources
Operating Activities, page 75

2.    Your analysis of changes in net cash provided by operating activities
cites non-cash items
      and changes in net income, which is on the accrual basis, as material
factors. Please
      revise your analysis to focus on factors that actually impact cash. Refer
to section IV.B.1
      of SEC Release No. 33-8350 for guidance.
 Russell Nickel
Funko, Inc.
May 6, 2019
Page 2
Notes to the Consolidated Financial Statements, page 91

3.       In view of the risk factor disclosed on page 43 in regard to your
status as a holding
         company and that you have no independent means of generating revenue
or cash flow, and
         your ability to pay dividends in the future, if any, is dependent upon
the financial results
         and cash flows of FAH, LLC and its subsidiaries and distributions you
receive from FAH,
         LLC, please explain to us your consideration of Rules 4-08(e), 5.04(c)
Schedule I and 12-
         04 of Regulation S-X.
        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 Aamira Chaudhry at 202-551-3389 or Doug Jones at 202-551-
3309 with any questions.



FirstName LastNameRussell Nickel                               Sincerely,
Comapany NameFunko, Inc.
                                                               Division of
Corporation Finance
May 6, 2019 Page 2                                             Office of
Transportation and Leisure
FirstName LastName