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May 22, 2019
Micha Kaufman
Chief Executive Officer
Fiverr International Ltd.
8 Eliezer Kaplan St.
Tel Aviv 6473409, Israel
Re: Fiverr International Ltd.
Registration Statement on Form F-1
Filed May 16, 2019
File No. 333-231533
Dear Mr. Kaufman:
We have reviewed your registration statement and have the following
comment. In our
comment, 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 comment applies 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 this comment, we may have additional comments.
Form F-1 filed May 16, 2019
Selected Consolidated Financial and Other Data, page 54
1. You provide the number of active buyers and buyer spend "for the three
months ended"
March 31, 2019 and 2018; however, on page 3 you provide similar metrics
for the twelve
months ended March 31, 2019. Please explain or revise. Also, considering
you attribute
quarter-over-quarter revenue growth to such metrics, if available please
provide us with,
and revise to disclose, quarterly active buyer and buyer spend data for
each period
presented or tell us why you do not believe that information is
important to investors.
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.
Micha Kaufman
Fiverr International Ltd.
May 22, 2019
Page 2
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.
You may contact Rebekah Lindsey, Staff Accountant at (202) 551-3303 or
Kathleen
Collins, Accounting Branch Chief at (202) 551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Matthew
Crispino, Staff
Attorney at (202) 551-3456 or Jan Woo, Legal Branch Chief at (202) 551-3453
with any other
questions.
Sincerely,
FirstName LastNameMicha Kaufman Division of
Corporation Finance
Office of
Information Technologies
Comapany NameFiverr International Ltd.
and Services
May 22, 2019 Page 2
cc: Marc D. Jaffe
FirstName LastName