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SEC Company Response from G WILLI FOOD INTERNATIONAL LTD (WILC) (CIK 0001030997) (WILC) — Jan 21, 2020

G WILLI FOOD INTERNATIONAL LTD (WILC) (CIK 0001030997)
Date: Jan. 21, 2020 · CIK: 0001030997 · Accession: 0001178913-20-000135

AI Filing Summary & Sentiment

Referenced dates: January 6, 2020

Date
January 21, 2020
Author
Not clearly detected
Form
CORRESP
Company
G WILLI FOOD INTERNATIONAL LTD (WILC) (CIK 0001030997)

Letter

Via Edgar Office of Trade & Services Division of Corporation Finance Securities and Exchange Commission Form 20-F for the Fiscal Year Ended December 31, Filed March 27, 2019 Response Dated December 23, 2019 File No. 0-29256

Re: G. Willi-Food International Ltd. (the “Company”)

Dear Mr. Phippen:

We enclose our response to the comment raised by the staff of the Securities and Exchange Commission (the “Staff”) in its comment letter, dated January 6, 2020 (the “Comment Letter”), with respect to the above-referenced Form 20-F for the fiscal year ended December 31, 2018 (the “Form 20-F”) and our response dated December 23, 2019.

For your convenience, the comment of the Staff has been restated below in its entirety in bold, with the response to the comment set forth immediately thereafter.

Form 20-F for the Fiscal Year Ended December 31, 2018

Item 19. Exhibits, page 90

1.

We note that your Form 20-F is incorporated by reference in Form S-8 filed October 14, 2014. As such, please provide the consents of your independent registered public accounting firms or tell us why consents are not required. Refer to Item 19 of Form 20-F.

The Company has filed an amended Form 20-F to provide the requested consent of its independent registered public accounting firm.

If you have any questions or concerns, please contact Mr. Joshua Ravitz, Adv. of Gross, Kleinhendler, Hodak, Halevy, Greenberg, Shenhav & Co. at 972-3-607-4480.

Very truly yours,
G. WILL-FOOD INTERATIONAL LTD.

Show Raw Text
CORRESP
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filename1.htm

      January 21, 2020

      Via Edgar

      Mr. Adam Phippen

      Office of Trade & Services

      Division of Corporation Finance

      Securities and Exchange Commission

      Washington, D.C. 20549

      Re:  G. Willi-Food International Ltd. (the “Company”)

      Form 20-F for the Fiscal Year Ended December 31,
        2018

      Filed March 27, 2019

      Response Dated December 23, 2019

      File No. 0-29256

      Dear Mr. Phippen:

      We enclose our response to the comment raised by the staff of the Securities and Exchange Commission (the “Staff”) in its comment letter, dated January 6, 2020 (the “Comment Letter”),
        with respect to the above-referenced Form 20-F for the fiscal year ended December 31, 2018 (the “Form 20-F”) and our response dated December 23, 2019.

      For your convenience, the comment of the Staff has been restated below in its entirety in bold, with the
        response to the comment set forth immediately thereafter.

      Form 20-F for the Fiscal Year Ended December 31, 2018

      Item 19. Exhibits, page 90

                1.

                  We note that your Form 20-F is incorporated by reference in Form S-8 filed October 14, 2014. As such, please provide the consents of your
                    independent registered public accounting firms or tell us why consents are not required. Refer to Item 19 of Form 20-F.

      The Company has filed an amended Form 20-F to provide the requested consent of its independent registered public
        accounting firm.

      If you have any questions or concerns, please contact Mr. Joshua Ravitz, Adv. of Gross, Kleinhendler, Hodak, Halevy, Greenberg,
        Shenhav & Co. at 972-3-607-4480.

                Very truly yours,

                G. WILL-FOOD INTERATIONAL LTD.

                By:

              /s/ Yitschak Barabi

              Yitschak Barabi

              Financial Manager

              cc Mr. Joshua Ravitz, Adv.