52 Menachem Begin Rd.

Tel Aviv-Yafo 6713701, Israel


June 7, 2021




United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.

Washington, D.C. 20549-6010


Attention:Lisa Etheredge, Robert Littlepage, Mitchell Austin, Jan Woo Ltd.
  Registration Statement on Form F-1 (File No. 333- 256182)


Ladies and Gentlemen:


In accordance with Rule 461 of under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form F-1, as amended (File No. 333-256182) (the “Registration Statement”) of Ltd. (the “Company”). We respectfully request that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on Wednesday, June 9, 2021, or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling John Slater at (212) 906-1675.


We understand that the staff of the Securities and Exchange Commission will consider this request as confirmation by the Company that it is aware of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact John Slater of Latham & Watkins LLP at the number set forth above.


Thank you for your assistance in this matter.


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June 7, 2021

Page 2


  Very truly yours, Ltd.


  By: /s/ Eliran Glazer
    Name: Eliran Glazer
    Title: Chief Financial Officer


cc:(via email)
 Roy Mann, Co-Chief Executive Officer, Ltd.
 Eran Zinmann, Co-Chief Executive Officer, Ltd.
 Eliran Glazer, Chief Financial Officer, Ltd.
 Shiran Nawi, General Counsel, Ltd.
 Marc D. Jaffe, Esq., Latham & Watkins LLP
 Ian D. Schuman, Esq., Latham & Watkins LLP