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Davis Polk & Wardwell llp 450
Lexington Avenue davispolk.com |
CONFIDENTIAL |
January 13, 2023
Re: SatixFy Communications Ltd.
Amendment No. 1 to Registration Statement on Form F-1
Filed December 16, 2022
File No. 333-268510
Attention: Evan Ewing, Jay Ingram
Division of Corporation Finance
Office of Manufacturing
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-3628
Ladies and Gentlemen:
On behalf of SatixFy Communications Ltd., a limited liability company organized under the laws of the State of Israel (“SatixFy”, or the “Company”), we are responding to the comment from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to Amendment No. 1 to the Company’s Registration Statement on Form F-1 filed on December 16, 2022 (the “Registration Statement”) contained in the Staff’s letter dated January 5, 2023 (the “Comment Letter”). In response to the comment set forth in the Comment Letter, the Company has amended the Registration Statement and is submitting it together with this response letter (“Amendment No. 2”).
Set forth below are the Company’s responses to the Staff’s comment. For convenience, the Staff’s comment is repeated below in italics, followed by the Company’s response to the comment. Capitalized terms used but not defined within this letter have the meanings ascribed to them in the revised Registration Statement.
Registration Statement on Form F-1
Aggregate Compensation of Directors and Executive Officers, page 133
| 1. | Please update your compensation disclosure to reflect the fiscal year ended December 31, 2022. |
| · | Response: The Company respectfully acknowledges the Staff’s comment and has revised page 134 of Amendment No. 2. |
Please do not hesitate to contact me at (212) 450-4111, (212) 701-5111 (fax) or michael.kaplan@davispolk.com if you have any questions regarding the foregoing or if I can provide any additional information.
| Very truly yours, | |
| /s/ Michael Kaplan | |
| Michael Kaplan |
| cc: | Yoav Leibovitch, Chairman of the Board of Directors |
| Oren Harari, Interim Chief Financial Officer |
Brian Wolfe
Davis Polk & Wardwell LLP
Tomer Fromovich
Ziv Haft Certified Public Accountants (Isr.), a member firm of BDO International Limited