SecProbe.io

CORRESP
1
filename1.htm

April 11, 2024

VIA EDGAR

Nicholas Panos

Shane Callaghan

Office of Mergers and Acquisitions

United States Securities and Exchange
Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

  Re:
  M&G Investment Management
  Limited

Freightos
Limited

Schedule
13D Filed by M&G Investment Management Limited

Filed
March 18, 2024

File
No. 005-94038

Dear Mr. Panos and Mr. Callaghan:

This letter, which is being
submitted on behalf of M&G Investment Management Limited (“M&G”), responds to the comments of the staff of
the United Securities and Exchange Commission (the “Staff”) contained in your letter dated April 9, 2024 (the “Comment
Letter”) with respect to the Schedule 13D filed by M&G on March 18, 2024 (the “Schedule 13D”). Today,
M&G has also filed an Amendment No. 1 to the Schedule 13D (“Amendment No. 1”), which contains revisions intended
to address certain comments of the Staff.

The responses set forth in
this letter are numbered so as to correspond to the numbering of the comments in the Comment Letter. For ease of reference, we have also
included the text of the applicable comment from the Comment Letter in boldface form below. Terms that are not otherwise defined herein
have the meanings ascribed to them in the Schedule 13D.

Schedule 13D Filed March 18, 2024

General

1. We note the date of the event reported as requiring the filing of the Schedule
13D was February 8, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing of a Schedule 13D within five business days after the
date beneficial ownership of more than five percent of a class of equity securities specified in Rule 13d-1(i)(1) was acquired. Based
on the February 8, 2024 event date, the Schedule 13D submitted on March 18, 2024 was not timely filed. Please advise us why the Schedule
13D was not filed within the required five business days after the date of the acquisition.

M&G respectfully advises
the Staff that the Schedule 13D was not filed within five business days after the February 8, 2024 appointment one of its employees
to the Issuer’s board of directors because of an administrative oversight, which occurred when M&G was not initially made
aware of the requirement to file a Schedule 13D at such time. M&G will be advised in future Schedule 13D filings by its own
securities counsel, and respectfully advises the Staff that future beneficial ownership filings by M&G will be timely and in
accordance with the deadlines set forth in the applicable federal securities law regulatory provisions.

April 11, 2024

2. We note that a Schedule 13G was previously filed on April 6, 2023 and was later
amended on February 13, 2024. Please mark the check box on the cover page of this Schedule 13D indicating that the filing person is filing
this schedule because of Rule 13d-1(e), Rule 13d- 1(f) or Rule 13d-1(g), or otherwise advise us of the basis for the transition from Schedule
13G to Schedule 13D.

M&G respectfully acknowledges
the Staff’s comment and has revised the cover page of Schedule 13D Amendment No. 1.

***

Please do not hesitate to contact
me at 212-504-6049 with any questions you may have regarding this letter or otherwise related to the Schedule 13D or Amendment No. 1.

    Sincerely,

    /s/
    Nick Ramphal

    Nick
    Ramphal, Esq.

    -2-