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Correspondence 0001193125-23-233452 from CHECK POINT SOFTWARE TECHNOLOGIES LTD (CHKP) (CIK 0001015922) (CHKP)

CHECK POINT SOFTWARE TECHNOLOGIES LTD (CHKP) (CIK 0001015922)
Date: Sept. 12, 2023 · CIK: 0001015922 · Accession: 0001193125-23-233452

AI Filing Summary & Sentiment

File numbers found in text: 000-28584

Referenced dates: September 7, 2023

Date
September 12, 2023
Author
WILSON SONSINI GOODRICH & ROSATI
Form
CORRESP
Company
CHECK POINT SOFTWARE TECHNOLOGIES LTD (CHKP) (CIK 0001015922)

Letter

Division of Corporation Finance Office of Technology Attention: Laura Veator, Senior Staff Accountant Re: Check Point Software Technologies Ltd. Form 20-F for the Fiscal Year Ended December 31, 2022 Filed April 27, 2023 File No. 000-28584

Dear Ms. Veator and Mr. Krikorian:

On behalf of our client, Check Point Software Technologies Ltd. (“Check Point” or the “Company”), we submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) contained in its letter dated September 7, 2023, relating to the above-referenced Form 20-F for the Company’s fiscal year ended December 31, 2022 filed April 27, 2023.

We have set out the comment from the Staff below in italicized, bold type and have followed the comment with the Company’s response.

In future 20-F filings, please include a discussion addressing the risk that the Company may be deemed an investment company, your reliance on Rule 3a-8, and the consequences if you do not comply with the rule’s conditions.

The Company respectfully advises the Staff that it will include the requested information in its future Form 20-F filings.

*****

AUSTIN BEIJING BOSTON BOULDER BRUSSELS HONG KONG LONDON LOS ANGELES NEW YORK PALO ALTO

SALT LAKE CITY SAN DIEGO SAN FRANCISCO SEATTLE SHANGHAI WASHINGTON, DC WILMINGTON, DE

Check Point

September 12,

Page 2

Please direct any questions regarding the Company’s responses to me at (650) 565-3574 or at rpavri@wsgr.com.

Sincerely,
WILSON SONSINI GOODRICH & ROSATI

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 Wilson Sonsini Goodrich & Rosati

Professional Corporation

1700 K Street NW

 Fifth Floor

Washington, D.C. 20006-3817

O: 202.973.8800

 F:
866.974.7329

 September 12, 2023

via electronic filing

 U.S. Securities and
Exchange Commission

 Division of Corporation Finance

 Office
of Technology

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention:       Laura Veator, Senior Staff Accountant

  Stephen Krikorian, Accounting Branch Chief

Re:
 Check Point Software Technologies Ltd.

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

Filed April 27, 2023

File No. 000-28584

Dear Ms. Veator and Mr. Krikorian:

 On
behalf of our client, Check Point Software Technologies Ltd. (“Check Point” or the “Company”), we submit this letter in response to comments from the staff (the “Staff”) of the Securities and
Exchange Commission (the “SEC”) contained in its letter dated September 7, 2023, relating to the above-referenced Form 20-F for the Company’s fiscal year ended December 31, 2022
filed April 27, 2023.

 We have set out the comment from the Staff below in italicized, bold type and have followed the comment with
the Company’s response.

 In future 20-F filings, please include a discussion addressing
the risk that the Company may be deemed an investment company, your reliance on Rule 3a-8, and the consequences if you do not comply with the rule’s conditions.

The Company respectfully advises the Staff that it will include the requested information in its future Form
20-F filings.

 *****

AUSTIN    BEIJING    BOSTON    BOULDER    BRUSSELS
  HONG KONG    LONDON    LOS ANGELES    NEW YORK    PALO ALTO

SALT LAKE CITY    SAN DIEGO    SAN
FRANCISCO    SEATTLE    SHANGHAI    WASHINGTON, DC    WILMINGTON, DE

 Check Point

 September 12,
2023

 Page 2

 Please direct any questions regarding the Company’s responses to me at (650) 565-3574 or at rpavri@wsgr.com.

Sincerely,

WILSON SONSINI GOODRICH & ROSATI

Professional Corporation

 /s/ Rezwan Pavri

Rezwan Pavri

cc:
 Roei Golan, Chief Financial Officer, Check Point Software Technologies Ltd.

Shira Yashar, General Counsel, Check Point Software Technologies Ltd.

Amy Caiazza, Wilson Sonsini Goodrich & Rosati, P.C.