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                            May 16, 2023

       Oran Holtzman
       Chief Executive Officer
       ODDITY Tech Ltd.
       8 Haharash Street
       Tel Aviv-Jaffa, 6761304, Israel

                                                        Re: ODDITY Tech Ltd.
                                                            Amendment No. 6 to
Draft Registration Statement on Form F-1
                                                            Submitted May 1,
2023
                                                            CIK No. 0001907085

       Dear Oran Holtzman:

             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. 6 to Draft Registration Statement on Form F-1, submitted
May 1, 2023

       Prospectus Summary
       Who We Are, page 1

   1.                                                   We note your response
to prior comment 2 and re-issue in part. Please revise the
                                                        Prospectus Summary,
where appropriate, to disclose SpoiledChild's revenues for the year
                                                        ended December 31,
2022.
   2.                                                   Your disclosure on page
119 indicates that the acquisition of Revela has not yet closed.
                                                        However, disclosure
throughout the prospectus appears to assume that the acquisition has
                                                        closed. For example, we
note your statement on page 7 that you are incorporating
                                                        Revela's molecules into
your current and future brands and your disclosure on page 119
 Oran Holtzman
FirstName  LastNameOran Holtzman
ODDITY Tech    Ltd.
Comapany
May        NameODDITY Tech Ltd.
     16, 2023
May 16,
Page 2 2023 Page 2
FirstName LastName
         identifies Revela's products ProCelinyl and Fibroquin as owned by
ODDITY LABS.
         Please tell us why it is appropriate for you to prominently discuss
Revela's business and
         its integration with your business, including the establishment of
ODDITY LABS, if the
         acquisition has not been consummated. To the extent the acquisition
has closed, please
         revise the prospectus, where appropriate, to describe the material
terms of the acquisition
         and file the definitive agreement as an exhibit to your registration
statement.
3.       We note your disclosure on page 1 that you "established ODDITY LABS to
bring
         artificial intelligence-based molecule discovery for the development
of science-backed,
         highly efficacious beauty and wellness products." Please revise this
disclosure here and
         elsewhere to clarify, if true, that the products you currently offer
are not drugs, biological
         products, or devices that have been determined by the FDA or similar
foreign regulators to
         be "efficacious" in treating diseases or other conditions. In this
regard, please explain to
         us why it is appropriate for you to use the terms "efficacious" and
"safe" to describe
         Revela's molecules and revise your disclosure to describe what is
meant by the term
         "efficacious."

         Please also revise your prospectus, where appropriate, to describe the
science that was
         performed, and the clinical trials that were conducted, to develop
Revela's molecules.
4.       We note your references here and throughout to Revela's "extensive
multi-category
         pipeline of novel molecules." Please revise the prospectus, where
appropriate, to describe
         these molecules and the categories they address.
Capitalization, page 80

5.       Please revise to include indebtedness, such as your loans and digital
security liability, as
         part of your capitalization table.
Management's Discussion and Analysis
Driving Customer Acquisition, Retention, and Repeat Purchases, page 85

6.       Refer to the prior comment number 4 and your response relating to the
presentation of net
         revenue repeat purchase rate, average order value, order billings from
paid and unpaid
         sources, and number of active customers. You state that you do not
believe the measures
         constitute material information necessary for an understanding or
evaluation of the
         Company's financial condition, changes in financial condition and
results of operations
         and you would not identify these measures as key performance
indicators as described in
         SEC Release No. 33-10751. You also state that you do not currently
intend to regularly
         disclose net revenue repeat purchase rate, average order value, order
billings from unpaid
         sources and paid sources, or number of active customers in future
periodic filings.
         However, you continue to include the disclosures prominently in the
filing. Please
         address the following:
             Based on the disclosure in the filing, it appears the measures
represent metrics for
              which the metric guidance would be applicable. In this regard, we
note that the net
 Oran Holtzman
ODDITY Tech Ltd.
May 16, 2023
Page 3
              revenue repeat purchase rate is disclosed throughout the filing,
including on page 4,
              which appears to emphasize the measure is a metric. In addition,
the presentation of
              charts for order billings from paid and unpaid sources appears to
provide emphasis on
              the measure. Please revise the filing to include the disclosures
requested, including a
              clear definition of each measure, the reason the measure is
useful to investors, how
              management uses the measure, and whether or not there are any
estimates or
              assumptions underlying the measure.
                Tell us how "net revenue" in "net revenue repeat purchase rate"
is calculated and if
              not consistent with GAAP, consider revising the nomenclature.
                Clarify the difference between average order value and average
order billings. If the
              terms are synonymous, revise the terms to be consistent
throughout.
Results of Operations
Comparison of Years Ended December 31, 2022 and 2021, page 88

7.       In order to provide a better understanding of your operations, please
quantify each factor
         noted related to the change in Revenues and Selling, General and
Administrative
         Expenses line items from the prior year. For example, you state that
the increase in net
         revenue is primarily due to increased orders from new customers,
increased orders from
         repeat customers, contribution from new brand and product categories.
Please quantify
         each of these factors in revised disclosure.
Non-GAAP Financial Measures, page 90

8.       We note your presentation of non-GAAP measures includes adjustments to
remove one-
         time bonuses, founder    incentive plan and new brand launch related
costs. Please clarify
         for us the nature of these costs and tell us how you considered the
guidance in
         Question 100.01 of the Non-GAAP Financial Measures Compliance and
Disclosure
         Interpretation.
Founder's Letter
ODDITY LABS is Bringing Pharma-Grade AI-Based Molecule Discovery to Beauty and
Wellness, page 106

9.       We note your disclosure on page 106 regarding ODDITY LABS and your
focus on
         "science-backed product development." Please revise this disclosure to
clarify whether
         you anticipate obtaining FDA approval for the products developed
through ODDITY
         LABS. If not, please remove your references to "Pharma-Grade . . .
Molecule Discovery"
         and explain what is meant by "science-backed product development."
10.    Please provide the basis for the statement that ODDITY LABS will
redefine product
FirstName LastNameOran Holtzman
       efficacy. In your revisions, please explain what is meant by product
efficacy and how the
Comapany    NameODDITY
       launch of ODDITY LABSTech Ltd.
                                   will redefine it. To the extent this
statement is based on
May 16,management   s
         2023 Page 3 belief, please so state.
FirstName LastName
 Oran Holtzman
FirstName  LastNameOran Holtzman
ODDITY Tech    Ltd.
Comapany
May        NameODDITY Tech Ltd.
     16, 2023
May 16,
Page 4 2023 Page 4
FirstName LastName
11.      Please revise to explain why the combination of your consumer platform
with Revela is a
         "game changer." To the extent this statement is based on management
s belief, please so
         state.
12.      Please revise to provide the basis for your statements that (i) legacy
businesses have
         underinvested in science, (ii) ingredient innovation has fallen behind
the curve, (iii)
         consumers are suffering and (iv) your competitors are    doing more of
the same for
         decades.
Business
Launching ODDITY LABS to Build the Future of Product Development, page 119

13.      We note your disclosure that "Procelinyl's powerful efficacy has been
validated in clinical
         studies." Please revise to clarify whether this product has been
approved by the FDA. To
         the extent this product has not been approved by the FDA, please tell
us why this language
         is appropriate. Additionally, please revise your disclosure to provide
further details
         regarding the clinical studies and consumer studies referenced in this
section, including
         the studies in which formulations with ProCelinyl outperformed
market-leading
         competitors and the clinical study related to Fibroquin.
Notes to the Consolidated Financial Statements
Note 2: Significant Accounting Policies
g. Digital Securities, page F-9

14.      Please revise to separately classify the Digital security liability on
the face of the financial
         statements. In addition, please tell us why presentation as a
long-term liability at
         December 31, 2022 is appropriate considering the securities will
convert into Class A
         ordinary shares upon your pending initial public offering. Please
disclose in Note 16 the
         number of securities issued and the issuance price per security.
       You may contact Sasha Parikh at 202-551-3627 or Mary Mast at
202-551-3613 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Joshua Gorsky at 202-551-7836 or Alan Campbell at 202-551-4224 with any
other
questions.



                                                                 Sincerely,

                                                                 Division of
Corporation Finance
                                                                 Office of
Industrial Applications and
                                                                 Services
cc:      Alison Haggerty