United States securities and exchange commission logo





                                March 13, 2023

       Zvi Schreiber
       Chief Executive Officer
       Freightos Limited
       Technology Park Building 2
       1 Derech Agudat Sport
       HaPo   el Jerusalem, Israel
       9695102

                                                        Re: Freightos Limited
                                                            Registration
Statement on Form F-1
                                                            Filed February 22,
2023
                                                            File No. 333-269911

       Dear Zvi Schreiber:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-1 filed February 22, 2023

       Cover Page

   1.                                                   For each of the
securities being registered for resale, please disclose the price that
                                                        the selling
securityholders paid for such securities.
   2.                                                   We note the warrants
are out the money. Please disclose the likelihood that warrant
                                                        holders will not
exercise their warrants. Provide similar disclosure in the prospectus
                                                        summary, risk factors,
MD&A and use of proceeds section and disclose that cash proceeds
                                                        associated with the
exercises of the warrants are dependent on the stock price. As
                                                        applicable, describe
the impact on your liquidity and update the discussion on the ability
 Zvi Schreiber
FirstName  LastNameZvi Schreiber
Freightos Limited
Comapany
March      NameFreightos Limited
       13, 2023
March2 13, 2023 Page 2
Page
FirstName LastName
         of your company to fund your operations on a prospective basis with
your current cash on
         hand.
Summary, page 11

3.       Please expand your discussion here to reflect the fact that this
offering involves the
         potential sale of a substantial portion of shares for resale and
discuss how such sales could
         impact the market price of the company   s common stock.
Risk Factors
Sales of Freightos Ordinary Shares, or the perception of such sales, by us or
the Selling
Securityholders pursuant to this prospectus in the, page 45

4.       Please expand your risk factor to disclose the purchase price of all
securities being
         registered for resale and that even though the current trading price
is significantly below
         Gesher I Acquisition Corp.'s IPO price, the private investors have an
incentive to sell
         because they will still profit on sales because of the lower price
that they purchased their
         shares than the public investors.
General

5.       Revise your prospectus to disclose the price that each selling
securityholder paid for the
         securities being registered for resale. Highlight any differences in
the current trading
         price, the prices that such selling securityholders acquired their
shares and warrants, and
         the price that public securityholders acquired their shares and
warrants. Please also
         disclose any potential profit the selling securityholders will earn
based on the current
         trading price.
6.       In light of the significant number of redemptions and the unlikelihood
that the company
         will receive significant proceeds from exercises of the warrants
because of the disparity
         between the exercise price of the warrants and the current trading
price of the Ordinary
         Shares, expand your discussion of capital resources to address any
changes in your
         liquidity position since the business combination. If you are likely
to have to seek
         additional capital, discuss the effect of this offering on your
ability to raise additional
         capital.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Zvi Schreiber
Freightos Limited
March 13, 2023
Page 3

       You may contact Cheryl Brown, Staff Attorney, at (202) 551-3905 or
Karina Dorin, Staff
Attorney, at (202) 551-3763 with any questions.



                                                         Sincerely,
FirstName LastNameZvi Schreiber
                                                         Division of
Corporation Finance
Comapany NameFreightos Limited
                                                         Office of Energy &
Transportation
March 13, 2023 Page 3
cc:       Stephen Alicanti, Esq.
FirstName LastName