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                            January 6, 2022

       Neal Menashe
       Chief Executive Officer
       Super Group (SGHC) Ltd
       Bordeaux Court, Les Echelons
       St. Peter Port, Guernsey, GY1 1AR

                                                        Re: Super Group (SGHC)
Ltd
                                                            Amendment No. 4 to
Registration Statement on Form F-4
                                                            Filed December 22,
2021
                                                            File No. 333-259395

       Dear Mr. Menashe:

              We have reviewed your amended registration statement and have the
following
       comment. In our comment, we may ask you to provide us with information
so we may better
       understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this comment, we may have additional comments.

       Amendment No. 4 to Registration Statement on Form F-4

       General

   1.                                                   We note your response
to comment 2 and your revised disclosure that no    covered
                                                        person    within the
meaning of Rule 14e-5(c)(3)(iv) will engage in any unlawful activity as
                                                        defined in Rule
14e-5(a) and that any repurchases to be made by or on behalf of SEAC or
                                                        its affiliates would
only be made in compliance with Rule 14e-5. Please provide your
                                                        analysis as to how
repurchases made by or on behalf of SEAC or its affiliates would
                                                        comply with Rule 14e-5,
given the definition of "covered person" provided in Rule 14e-
                                                        5(c)(3)(i).
Alternatively, please revise your disclosure to clarify that there will be no
                                                        repurchases made by or
on behalf of SEAC or its affiliates.
 Neal Menashe
FirstName  LastNameNeal
Super Group  (SGHC) Ltd Menashe
Comapany
January    NameSuper Group (SGHC) Ltd
        6, 2022
January
Page 2 6, 2022 Page 2
FirstName LastName
       Please contact Taylor Beech at 202-551-4515 or Dietrich King at
202-551-8071 with
any questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Trade &
Services
cc:      Rachel D. Phillips, Esq.