November 27, 2018

Moshe Mizrahy
Chief Executive Officer
InMode Ltd.
Tavor Building, Sha'ar Yokneam
P.O. Box 533
Yokneam 2069200, Israel

       Re: InMode Ltd.
           Amendment No. 3 to
           Draft Registration Statement on Form F-1
           Submitted November 8, 2018
           CIK No. 0001742692

Dear Mr. Mizrahy:

      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.
 Moshe Mizrahy
FirstName LastNameMoshe Mizrahy
InMode Ltd.
Comapany 27, 2018
November NameInMode Ltd.
November 27, 2018 Page 2
Page 2
FirstName LastName
Draft Form F-1 submitted November 8, 2018

Risk Factors, page 12

1.       Please expand your response to prior comment 1, providing us with your
analysis of the
         company's reliance on rule 3a-2(b) under the Investment Company Act.
In the risk factor
         disclosure on the company's investment company status, please add a
precise discussion
         of rule 3a-2(b), including the date on which the company exceeded the
40% asset
         threshold under Section 3(a)(1)(C) of the Investment Company Act.
Please clarify that
         such a date marks the beginning of the one-year safe harbor for
transient companies under
         rule 3a-2. Please disclose the extent to which the company's reliance
on the one-year safe
         harbor would be affected by the starting date of the safe harbor.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
51

2.       Please expand your response to prior comment 3 to (1) tell us how you
determined to
         group your products for purposes of your disclosure on page 52 given
the categories that
         you mention on page 3, (2) clarify why products tailored to the needs
of international
         customers cannot be included in your disclosure regarding revenue from
the products you
         mention on page 52, and (3) tell us the portion of your revenue
derived from the Fractora
         hand piece during the periods presented in your financial statements.
Also, given your
         disclosure in the table on page 79, it is unclear whether the Contoura
platform or products
         you no longer sell have contributed the balance of your revenue where
your disclosure on
         page 52 does not total 100% of United States revenue; please clarify.
Components of Our Results of Operations, page 52

3.       We note that your response to prior comment 5 discloses your 2016
revenue from
         consumables and extended warranties combined. Please tell us the
portion of your
         revenue from consumables in 2016. In this regard, please reconcile the
statement in your
         October 11, 2018 letter to us that you expect a similar breakdown from
consumables and
         warranties and service contracts for the foreseeable future with your
disclosure on page 5
         of your prospectus that your strategy includes your expectation that
the percentage of your
         revenues attributable to consumables will increase as your customer
base grows.
Business, page 68

4.       Your disclosure on page 31 in response to prior comment 2 appears to
address the
         conditions and procedures for which two of your products have received
regulatory
         clearance for marketing in the United States. In an appropriate
section of your document,
         please clarify the conditions and procedures for which you have
received the required
         regulatory clearance to market each of your material products in each
material
         jurisdiction.
 Moshe Mizrahy
InMode Ltd.
November 27, 2018
Page 3
Joint Venture Equity Interest Conversion, page 114

5.    We note your response to prior comment 8. If your U.K. joint venture is
based on a non-
      binding document as indicated in exhibit 10.12, please revise your
prospectus disclosure
      regarding the joint venture to clarify.
        You may contact Jeanne Bennett at 202-551-3606 or Brian Cascio,
Accounting Branch
Chief, at 202-551-3676 if you have questions regarding comments on the
financial statements
and related matters. Please contact Heather Percival at 202-551-3498 or Russell
Mancuso, Branch Chief, at 202-551-3617 with any other questions.



                                                          Sincerely,
FirstName LastNameMoshe Mizrahy
                                                          Division of
Corporation Finance
Comapany NameInMode Ltd.
                                                          Office of Electronics
and Machinery
November 27, 2018 Page 3
cc:       Brian D. Hirshberg
FirstName LastName