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CORRESP
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      January 21, 2025

Securities
and Exchange Commission

Division
of Corporate Finance

100
F Street, N.E.

Washington,
D.C. 20549

Attention: Division
of Corporation Finance

  Office of Technology

VIA
EDGAR

 Re: Viewbix
                                            Inc. (the “Company,” “Viewbix,” “we” or “us”)

Form
10-K for the Year Ended December 31, 2023

Filed
March 25, 2024

Form
10-Q for the Quarter Ended September 30, 2024

Filed
November 19, 2024

File
No. 000-15746

Dear
Madam or Sir:

We
hereby provide the following responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) concerning the above-referenced filings that were provided to the Company by the Staff in its letter
dated December 20, 2024 and delivered to the Company on January 14, 2025 (the “Comment Letter”). To assist your review,
we have retyped the text of the Staff’s comments below in bold face type and have provided the Company’s responses immediately
following each numbered comment.

Form
10-K for the Year Ended December 31, 2023

Liquidity
and Capital Resources, page 52

1. We
                                            note your discussion of cash flows repeats line items in the statement of cash flows, but
                                            does not provide investors with insight as to underlying reasons for changes. In future filings,
                                            please revise and expand your disclosure to provide such insight in accordance with Item
                                            303(b) of Regulation S-K.

Company
Response: We respectfully acknowledge the Staff’s comment, and will provide additional disclosures related to the cash flows
and the underlying reasons for changes in our future filings.

Item
9A Controls and Procedures, page 56

2. We
                                            note that your disclosure controls and procedures were not effective as of December 31, 2022,
                                            and that there appears to be no representation on page 55 about the effectiveness of Disclosure
                                            Controls and Procedures as of December 31, 2023. In future filings, please provide management’s
                                            assessment regarding the effectiveness of both the Company’s disclosure controls and
                                            procedures and internal control over financial reporting as of the end of the most recent
                                            fiscal year in accordance with Item 9A of Form 10-K.

Company
Response: We respectfully acknowledge the Staff’s comment, and will provide additional quantitative disclosures regarding management’s
assessment regarding the effectiveness of both the Company’s disclosure controls and procedures and internal control over financial
reporting in our future filings.

SEC Division of Corporation Finance

Office of Technology

January 21, 2025

Page 2

Form
10-Q for the Quarter Ended September 30. 2024

Financial
Statements

Notes
to Interim Condensed Consolidated Financial Statements

Note
5: Goodwill and Intangible Assets, Net, page 19

 3. Tell
                                            us how you considered the need to evaluate the recovery of your customer relations and technology
                                            intangible assets as of September 30, 2024 in light of the adverse impacts due to industry
                                            technological changes and your loss of customers. Refer to ASC 350-30-35-14 and ASC 360-10-35-21.

Company
Response: The Company has two main activities that are reported as separate operating segments: the search segment, which activity
is conducted by the Company’s subsidiary Gix Media Ltd., and the digital content segment, which activity is conducted by the Company’s
subsidiary Cortex Media Group Ltd.

The
carrying amount of intangible assets, including goodwill, as of September 30, 2024 and June 30, 2024, was largely comprised of intangible
assets related to the digital content segment, constituting approximately 82% of the overall net balance of intangible assets, as illustrated
in the following table:

    Intangible Assets, Net

    30/09/2024
    30/06/2024

    Digital content
    Search segment
    Total
    Digital content
    Search segment
    Total

    Customer Relations
      3,385
      550
      3,935
      3,577
      581
      4,158

    Technology
      4,827
      1,437
      6,264
      5,183
      1,542
      6,725

    Goodwill (before impairment)
      6,432
      1,083
      7,515
      11,171
      1,083
      12,254

    Internal-use Software
      -
      74
      74
      -
      113
      113

    Deferred Taxes
      (986 )
      (238 )
      (1,224 )
      (1,051 )
      (255 )
      (1,306 )

    Total Intangible Assets, Net
      13,658
      2,906
      16,564
      18,880
      3,064
      21,944

    Net Working Capital

      (782 )
      (1,401 )
      (2,183 )

    Carrying Value before Impairment

      18,098
      1,663
      19,761

    Carrying Value after Impairment

      13,359
      1,663
      15,022

    Goodwill Impairment

      4,739
      -
      4,739

During
the nine months period ending September 30, 2024, we recorded a goodwill impairment loss in the digital content segment of $4,739.

SEC
Division of Corporation Finance

Office
of Energy and Transportation

January
21, 2025

Page
3

Our
qualitative assessments to determine whether it is necessary to perform the quantitative impairment tests, with respect to customer relationships
and technology intangible assets as well as with respect to goodwill, and in relation to both of our operating segments, resulted in
the performance of quantitative impairment tests in accordance with ASC 360 with respect to customer relationships and technology intangible
assets in the performance of quantitative impairment tests in accordance with ASC 350 with respect to goodwill, as further described
below. These quantitative impairment tests resulted in no impairment loss recognized with respect to customer relationships and technology
intangible assets and with respect to goodwill in our search segment, and in an impairment loss of $4,739 thousand recognized with respect
to goodwill of our digital content segment and no impairment loss recognized with respect to customer relationships and technology intangible
assets of that segment.

We
respectfully advise the staff that while impairment loss was recognized with respect to goodwill of the digital content operating segment,
no impairment loss was recognized with respect to customer relationships and technology intangible assets of that segment due to the
different quantitative impairment test methods prescribed in ASC 360 and ASC 350 for the performance of these quantitative tests. In
accordance with ASC 360 the carrying amount of a long-lived asset or an asset group is not recoverable and an impairment loss is recognized
if that carrying value exceeds the sum of the undiscounted cash flows expected to result from the use and eventual disposition
of the asset or asset group, while in accordance with ASC 350 If the carrying amount of a reporting unit exceeds its fair value, which
fair value is generally is calculated using discounted cash flows, an impairment loss is recognized in goodwill in an amount equal
to that excess.

More
specifically, we have performed the following steps in our testing for impairment with respect to intangible assets and goodwill in both
of our operating segments:

 ● We
                                            performed the quantitative impairment test in accordance with ASC 360 with respect to customer
                                            relationships and technology intangible assets, as follows:

 ◌ In
                                            accordance with ASC 360-10-35-23 through 35-25, which prescribe the criteria for grouping
                                            of assets for the purposes of testing impairment of intangible assets, we concluded cashflows
                                            generated from customer relationships and technology intangible assets in each of or our
                                            two reporting units are not independent of the cash flows of the other assets and liabilities
                                            within each of these reporting units. Accordingly, we identified all assets and liabilities
                                            of each of our reporting units as a single asset group for purposes of measurement of intangible
                                            assets impairment loss.

 ◌ In
                                            accordance with ASC 360-10-35-26, which prescribes the criteria for the inclusion of goodwill
                                            in an asset group, we included the respective carrying value of goodwill of each the two
                                            asset groups, as each of these asset groups is a reporting unit (which we also identified
                                            as a reportable segment - Note 11).

 ◌ In
                                            accordance with ASC 360-10-35-17, we compared the undiscounted cash flows expected
                                            to result from the use and eventual disposition of each of the two asset groups and concluded
                                            that an impairment loss is not to be recognized with respect to customer relationships and
                                            technology intangible assets in either segments, as the undiscounted cash flows expected
                                            to result from these asset groups of $3,201 and $26,617 in the search and digital content
                                            segments, respectively, exceeded the search and digital content asset group carrying amounts
                                            of $1,663 and 18,098$, respectively.

 ● We
                                            proceeded to perform the quantitative goodwill impairment test of each of our two reporting
                                            units in accordance with ASC 350-20-35:

 ◌ In
                                            our digital content reporting unit, our quantitative goodwill impairment test resulted in
                                            an impairment loss of $4,739 thousands, which in accordance with ASC 350-20-35-8 we recognized
                                            in goodwill (Note 5), given that the carrying value of this reporting unit of $18,098 exceeded
                                            our estimated fair value of this reporting unit of $13,359 by that amount.

SEC Division of
Corporation Finance

Office of Technology

January 21, 2025

Page 4

 ◌ In
                                            our search reporting unit, our quantitative goodwill impairment test resulted in no impairment
                                            loss being recognized given our estimated fair value of this reporting unit of $1,944 exceeded
                                            its carrying value of $1,663.

Management’s
Discussion and Analysis

Results
of Operations, page 42

 4. We
                                            note continuing material decline of Gix Media Search Platform revenues. In future filings,
                                            quantify direct model search referral and revenue losses due to changes and updates to browser
                                            technologies. Please also quantify how the number of indirect model searches received from
                                            third party strategic partners has changed between periods. Address known trends and uncertainties
                                            that are expected to have a material impact on these sources of revenues. Refer to Item 303(c)
                                            of Regulation S-K.

Company
Response: We respectfully acknowledge the Staff’s comment, and will provide additional disclosures in future filings that quantify
model search referral and revenue losses due to changes and updates to browser technologies, quantify how the number of indirect model
searches received from third party strategic partners has changed between periods in our future filings, and address known trends and
uncertainties that are expected to have a material impact on these sources of revenues.

We
appreciate your time and attention to our responses to the Staff’s comments set forth in this letter. Should you wish to discuss
this letter at any time, please do not hesitate to contact me at +972 536666611.

   Sincerely,

  /s/ Amihay Hadad

   Chief
Executive Officer

   Viewbix
Inc.

  cc:
   Joseph
Kempf

  Lisa
Haynes Etheredge

  (Securities
and Exchange Commission)