May 13, 2019

Hengming Yang
President and Chief Executive Officer
Wanda Sports Group Company Limited
9/F, Tower B, Wanda Plaza
93 Jianguo Road, Chaoyang District
100022, Beijing
People's Republic of China

       Re: Wanda Sports Group Company Limited
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted April 26, 2019
           CIK No. 0001771279

Dear Mr. Yang:

      We have reviewed your amended draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Form DRS/A

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-IFRS Financial Measures, page 67

1.     We note that your EBITDA measure adjusts for "net financial
(income)/expenses." We
       further note from note 13 that items other than interest comprise this
total that include
       bank charges, loss on derivatives, and foreign exchange losses/gains.
Please note that
       EBITDA, by definition, should only reflect adjustments for interest,
taxes, depreciation
       and amortization. In this regard, please revise to remove these other
adjustments from
       your calculation of EBITDA or alternatively, you may include such
adjustments in your
 Hengming Yang
FirstName LastNameHengmingLimited
Wanda Sports Group Company Yang
Comapany NameWanda Sports Group Company Limited
May 13, 2019
May 13, 2019 Page 2
Page 2
FirstName LastName
         calculation of Adjusted EBITDA. Please refer to Question 103.01 of the
Commission s
         Compliance and Disclosure Interpretations: Non-GAAP Measures dated
April 4, 2018.
Revenue from contracts with customers applicable from January 1, 2018, page
F-16

2.       We note that you may act as principal or agent under your sale of
rights contracts per page
         F-17. In this regard, for each significant type of contract where you
have determined that
         you are either principal or agent, please tell us the assumptions and
considerations
         included in how you determine that you do or do not control the
specified service
         according to paragraph B37 of IFRS 15. Also, please consider revising
your discussion of
         your revenue recognition for these business models to be consistent
with the type of
         contracts/services discussed in MD&A. In this regard, we note that
MD&A discusses
         commissions based contracts, sale of services general contractor, sale
of services cost
         plus. Please ensure these different types of contracts are discussed
in terms of principal
         versus agent considerations as applicable.
3.       We note from your discussion in MD&A that reimbursement revenue
represented a
         significant amount of the revenue increase in 2018 from 2017. We
further note from your
         disclosure on page 74 that reimbursement revenues result from the
cost-plus contractual
         model and are either recognized as revenue when received from
broadcasters and passed
         on to the rights owner, or through compensation by the rights owner of
direct costs
         incurred depending on the contract terms. However, it is unclear from
your disclosure in
         Note 2 to the financial statements where the revenue recognition
related to
         these reimbursement revenues and cost plus contracts is discussed.
Please advise. Also,
         please provide us more information on the nature of these
reimbursement revenues and
         address how the recording of these amounts as revenue complies with
IFRS 15.
4.       We note from your discussion in MD&A on page 130 that in both your
Spectator Sports
         and DPSS segments, you apply your in-house DPSS capabilities. Revenue
and costs with
         respect to these services are generally allocated to the Spectator
Sports segment if
         provided in the same contract that includes a rights-in arrangement
with a rights-in partner
         or as part of a rights-out arrangement with a rights-out client.
Please revise your notes to
         the financial statements to discuss the determination of performance
obligations related to
         these services and how you determine the allocation of transaction
price, as applicable.
         See guidance in paragraph 123(b) of IFRS 15.
11.1 Disaggregated revenue information, page F-81

5.       We note from your discussion in MD&A and in your revenue recognition
policies, that
         you appear to have many revenue streams, including sponsorship, media
production, event
         entry fees, digital services, and licensing. However, in Note 4, in
addition to providing
         revenues by segment, you have disaggregated revenue only by geography.
In accordance
         with paragraph 114 of IFRS 15, please revise to disaggregate revenue
by categories that
         depict how the nature, amount, timing, and uncertainty of revenue are
affected by
         economic factors. Please refer to paragraphs B87-89 of IFRS 15.
 Hengming Yang
Wanda Sports Group Company Limited
May 13, 2019
Page 3

        You may contact Heather Clark, Staff Accountant, at 202-551-3624 or
Claire
Erlanger, Staff Accountant, at 202-551-3301 if you have questions regarding
comments on the
financial statements and related matters. Please contact Ruairi Regan at
202-551-3269 or
Brigitte Lippmann at 202-551-3713 with any other questions.



                                                          Sincerely,
FirstName LastNameHengming Yang
                                                          Division of
Corporation Finance
Comapany NameWanda Sports Group Company Limited
                                                          Office of
Transportation and Leisure
May 13, 2019 Page 3
cc:       Mark Bergman, Esq.
FirstName LastName