United States securities and exchange commission logo





                             January 18, 2022

       Mark D. Roberson
       Chief Executive Officer
       Strong Global Entertainment, Inc.
       4201 Congress Street, Suite 175
       Charlotte, NC 28209

                                                        Re: Strong Global
Entertainment, Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted December
23, 2021
                                                            CIK No. 0001893448

       Dear Mr. Roberson:

             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.

       Amendment No. 1 to Draft Registration Statement on Form S-1

       Prospectus Summary, page 1

   1.                                                   We note your revisions
in response to prior comment 4. Please file your supply contracts
                                                        with AMC, IMAX and
Cinemark as exhibits or provide us your basis for not filing
                                                        them pursuant to
Regulation S-K, Item 601(b)(10).
       Use of Proceeds, page 32

   2.                                                   Please revise to
disclose here and in the risk factor on page 23 the estimated amount that
                                                        you expect to spend in
order to bring the Joliette Plan into compliance with certain codes
                                                        and environmental
permits.
 Mark D. Roberson
Strong Global Entertainment, Inc.
January 18, 2022
Page 2
Description of Securities, page 71

3.     We note your revisions in response to prior comment 14 and reissue. We
note that you
       refer shareholders to, in part, the applicable provisions of the BCBCA.
It is not
       appropriate to qualify your disclosure by reference to information that
is not included in
       the filing or filed as an exhibit. Please revise accordingly.

Consolidated Financial Statements
Note 4. Inventory, page F-16

4.     Please address the following regarding your response to prior comment
four:
           Please revise Note 4 or Management's Discussion and Analysis to
quantify the
           percentage of your finished goods that reserved for impairment or
obsolescence, and
           discuss the reasons this percentage is so high for the periods
presented.
           To the extent you continue to believe that a tabular rollforward of
your inventory
           reserves is not necessary, revise to provide a narrative rollforward
that separately
           quantifies the components for each period presented.

       You may contact Christine Torney at 202-551-3652 or Kevin Vaughn at
202-551-3494 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Joshua Gorsky at 202-551-7836 or Ada D. Sarmento at 202-551-3798 with
any other
questions.



                                                             Sincerely,
FirstName LastNameMark D. Roberson
                                                             Division of
Corporation Finance
Comapany NameStrong Global Entertainment, Inc.
                                                             Office of Life
Sciences
January 18, 2022 Page 2
cc:       Janeane R. Ferrari, Esq.
FirstName LastName