November 25, 2024

Stephen Lazarus
Chief Financial Officer
OneSpaWorld Holdings Limited
Harry B. Sands, Lobosky Management Co. Ltd.
Office Number 2
Pineapple Business Park
Airport Industrial Park
Nassau, Island of New Providence, Commonwealth of The Bahamas

       Re: OneSpaWorld Holdings Limited
           Form 10-K for Fiscal Year Ended December 31, 2023
           File No. 001-38843
Dear Stephen Lazarus:

       We have reviewed your filing and have the following comment(s).

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2023
Item 6. Selected Financial Data
Note Regarding Non-GAAP Financial Information, page 36

1.     Please revise to disclose the reasons why management believes that
presentation of
       Unlevered After Tax Cash Flow provides useful information to investors
regarding
       financial condition and/or results of operations. Refer to Item
10(e)(1)(i)(C) of
       Regulation S-K.
 November 25, 2024
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Comparison of Results for the Years Ended December 31, 2023 and 2022
Results of Operations , page 41

2.     Please revise your discussion to quantify factors to which changes are
attributed. In
       addition, with regard to revenue discussions, please quantify the extent
to which
       changes are attributable to changes in prices or to changes in the
volume or amount of
       products or services being sold or to the introduction of new products
or services.
       Refer to Item 303(b)(2) of Regulation S-K. We note discussion in your
February 28,
       2024 earnings call regarding the impact of pre-booking on your business.
Please also
       consider disclosure of this factor. Please provide us a copy of your
intended, revised
       disclosure.
Liquidity and Capital Resources
Cash Flows, Comparison of Results for the Years Ended December 31, 2023 and
2022
Operating Activities, page 45

3.     Please provide a more informative analysis and discussion of changes in
cash flows,
       including changes in working capital components, for each period
presented. In doing
       so, explain the underlying reasons and implications of material changes
between
       periods to provide investors with an understanding of trends and
variability in cash
       flows. Ensure your discussion and analysis is not merely a recitation of
changes
       evident from the financial statements. Refer to Item 303(a) of
Regulation S-K.

        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.

       Please contact Robert Shapiro at 202-551-3273 or Lyn Shenk at
202-551-3380 if you
have questions regarding comments on the financial statements and related
matters.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services