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Correspondence 0001178913-23-002262 from CHECK POINT SOFTWARE TECHNOLOGIES LTD (CHKP) (CIK 0001015922) (CHKP)

CHECK POINT SOFTWARE TECHNOLOGIES LTD (CHKP) (CIK 0001015922)
Date: June 21, 2023 · CIK: 0001015922 · Accession: 0001178913-23-002262

AI Filing Summary & Sentiment

File numbers found in text: 000-28584

Referenced dates: June 8, 2023

Date
June 21, 2023
Author
Not clearly detected
Form
CORRESP
Company
CHECK POINT SOFTWARE TECHNOLOGIES LTD (CHKP) (CIK 0001015922)

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Corporate Finance, Office of Technology Re: Check Point Software Technologies Ltd. Form 20-F for the year ended December 31, 2022 Filed April 27, 2023 File No. 000-28584

Dear Ms. Laura Veator and Mr. Stephen Krikorian:

Check Point Software Technologies Ltd. (the “Company”) provides the following information in response to the comment contained in the correspondence of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated June 8, 2023, relating to the aforementioned Form 20-F. For reference purposes, the text of your letter dated June 8, 2023, has been reproduced herein (in bold), with the Company’s response below.

Form 20-F for the Fiscal Year ended December 31, 2022

Consolidated Financial Statements

Notes to Consolidated Financial Statements

Note 4, Cash and Cash Equivalents, Short-Term Bank Deposits and Marketable Securities, Page F-28

1.

Please provide us with a breakdown of your marketable securities by the following categories, for each period presented. Please also revise your future 20-F filings to include this information. We refer you to ASC 320-10-50-1B.

Debt securities issued by the U.S. Treasury and other U.S. government agencies

Debt securities issued by other governments

Corporate debt securities

June 21, 2023

Page 2

Response:

We acknowledge the Staff’s comment and respectfully advise the Staff that we have provided below a breakdown of our marketable securities for each category requested by the Staff and for each period presented. We further respectfully advise the Staff that we will include this information in our future Form 20-F filings.

In Million USD

December 31,

Marketable securities:

Debt securities issued by the U.S. Treasury and other U.S. government agencies

819.3

883.9

Debt securities issued by other governments

118.3

114.0

Corporate debt securities

1,938.5

2,021.1

Total Marketable securities

2,876.1

3,019.0

If you have any questions or comments with respect to the foregoing, please contact the undersigned at (972) 547716704 or by email at roeego@checkpoint.com, or Rezwan D. Pavri of Wilson Sonsini Goodrich & Rosati, P.C., at (650) 565-3574 or by email at rpavri@wsgr.com.

Sincerely,
Check Point Software Technologies Ltd.

Show Raw Text
CORRESP
1
filename1.htm

      June 21, 2023

        VIA EDGAR

      Ms. Laura Veator

      Mr. Stephen Krikorian

        United States Securities and Exchange Commission

        Division of Corporate Finance, Office of Technology

        100 F Street, NE

        Washington, D.C. 20549

      Re:         Check Point Software Technologies Ltd.

      Form 20-F for the year ended December 31, 2022

      Filed April 27, 2023

      File No. 000-28584

      Dear Ms. Laura Veator and Mr. Stephen Krikorian:

      Check Point Software Technologies Ltd. (the “Company”) provides the following information in response to the
        comment contained in the correspondence of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated June 8, 2023, relating to the aforementioned Form 20-F. For reference purposes, the text of your letter
        dated June 8, 2023, has been reproduced herein (in bold), with the Company’s response below.

      Form 20-F for the Fiscal Year ended December 31, 2022

      Consolidated Financial Statements

      Notes to Consolidated Financial Statements

      Note 4, Cash and Cash Equivalents, Short-Term Bank Deposits and Marketable Securities,
          Page F-28

            1.

              Please provide us with a breakdown of your marketable securities by the following categories, for each period presented. Please also
                revise your future 20-F filings to include this information. We refer you to ASC 320-10-50-1B.

            •

              Debt securities issued by the U.S. Treasury and other U.S. government agencies

            •

              Debt securities issued by other governments

            •

              Corporate debt securities

        June 21, 2023

        Page 2

      Response:

      We acknowledge the Staff’s comment and respectfully advise the Staff that we have
        provided below a breakdown of our marketable securities for each category requested by the Staff and for each period presented.  We further respectfully advise the Staff that we will include this information in our future Form 20-F filings.

      In Million USD

              December 31,

               2022

              2021

              Marketable securities:

              Debt securities issued by the U.S. Treasury and other U.S. government agencies

              819.3

              883.9

              Debt securities issued by other governments

              118.3

              114.0

              Corporate debt securities

              1,938.5

              2,021.1

              Total Marketable securities

              2,876.1

              3,019.0

      If you have any questions or
          comments with respect to the foregoing, please contact the undersigned at (972) 547716704 or by email at roeego@checkpoint.com, or Rezwan D. Pavri of Wilson Sonsini Goodrich & Rosati, P.C., at (650) 565-3574 or by email at rpavri@wsgr.com.

              Sincerely,

              Check Point Software Technologies Ltd.

                By:

              /s/ Roei Golan

              Roei Golan

              Chief Financial Officer

      cc:          Shira Yashar, Check Point Software Technologies Ltd.

      Rezwan D. Pavri, Wilson Sonsini Goodrich & Rosati, P.C.

      Tuvia J. Geffen, Naschitz, Brandes, Amir & Co.

      Eldan Levy, Kost,
          Forer, Gabbay & Kasierer, a Member of EY Global