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53rd at Third | |
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February 1, 2019 |
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CONFIDENTIAL SUBMISSION
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporate Finance
100 F Street, NE Washington, DC 20549
RE: Confidential Submission of Draft Registration Statement on Form F-1 for Fiverr International Ltd.
Ladies and Gentlemen:
On behalf of Fiverr International Ltd., a private company with limited liability incorporated under the Companies Law, 5759-1999 of the State of Israel (the Company), we hereby confidentially submit a draft Registration Statement on Form F-1 (the Registration Statement) of the Company as an Emerging Growth Company pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act of 2012 and Section 24(b)(2) of the Securities Exchange Act of 1934 for non-public review by the Staff of the U.S. Securities and Exchange Commission (the Staff) prior to the public filing of the Registration Statement.
Pursuant to Section 71003 of the Fixing Americas Surface Transportation Act and based on guidance issued by the Staff in connection therewith, the Company is omitting from the Registration Statement its annual financial statements as of and for the year ended December 31, 2016 as well as unaudited interim financial information as of and for the period ended June 30, 2018, because it reasonably believes that such financial statements will not be required to be included in the Registration Statement at the time of the contemplated offering.
If you have any questions with respect to this confidential submission, please call me at (212) 906-1281.
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Best regards, |
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/s/ Marc D. Jaffe |
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Marc D. Jaffe |
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of LATHAM & WATKINS LLP |
Enclosure
cc: |
Micha Kaufman, Fiverr International Ltd. |
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Ofer Katz, Fiverr International Ltd. |
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Ian D. Schuman, Latham & Watkins LLP |
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Joshua Kiernan, Latham & Watkins LLP |
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Adam J. Gelardi, Latham & Watkins LLP |