United States securities and exchange commission logo November 25, 2022 Ross Levinsohn Chief Executive Officer Arena Group Holdings, Inc. 200 Vesey Street 24th Floor New York, New York 10281 Re: Arena Group Holdings, Inc. Form 10-K for the fiscal year ended December 31, 2021 Filed April 1, 2022 File No. 001-12471 Dear Ross Levinsohn: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Technology