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Correspondence 0001213900-23-087806 from FORMULA SYSTEMS (1985) LTD (FORTY) (CIK 0001045986) (FORTY)

FORMULA SYSTEMS (1985) LTD (FORTY) (CIK 0001045986)
Date: Nov. 16, 2023 · CIK: 0001045986 · Accession: 0001213900-23-087806

AI Filing Summary & Sentiment

File numbers found in text: 000-29442

Referenced dates: November 6, 2023

Date
November 16, 2023
Author
/s/ Asaf Berenstin
Form
CORRESP
Company
FORMULA SYSTEMS (1985) LTD (FORTY) (CIK 0001045986)

Letter

Securities and Exchange Commission Division of Corporate Finance Attention: Division of Corporation Finance, Office of Technology VIA EDGAR Form 20-F for the Fiscal Year Ended December 31, 2022 File No. 000-29442

Re: Formula Systems (1985) Ltd. (the “Company”)

Dear Madams and Sirs:

We have received the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) concerning the above-referenced filing that were provided to the Company by the Staff in its letter dated November 6, 2023 (the “Comment Letter”).

As mentioned on the telephone by our external legal counsel, Jonathan M. Nathan of Meitar Law Offices, on November 16, 2023, we are unable to respond to the Comment Letter within the initial ten business day period provided for in the Comment Letter. This is due to the Company’s, and its publicly-traded subsidiaries’, current engagement in their reporting processes for the third quarter of 2023. We expect to file our response letter within an additional eight calendar day period following the initial due date, i.e., by Thursday, November 30, 2023.

We appreciate your attention to this letter. Should you wish to discuss this letter or the Comment Letter at any time, please do not hesitate to contact our legal counsel, Meitar Law Offices (Mike Rimon, Adv. at 011-972-3-610-3621 or Jonathan M. Nathan, Adv. at 011-972-52-312-5574).

Sincerely,
/s/ Asaf Berenstin

Show Raw Text
CORRESP
1
filename1.htm

November 16, 2023

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:
    Formula Systems (1985) Ltd. (the “Company”)

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

    File No. 000-29442

Dear Madams and Sirs:

We have received the comments of the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) concerning the above-referenced
filing that were provided to the Company by the Staff in its letter dated November 6, 2023 (the “Comment Letter”).

As mentioned on the telephone by our external
legal counsel, Jonathan M. Nathan of Meitar Law Offices, on November 16, 2023, we are unable to respond to the Comment Letter within the
initial ten business day period provided for in the Comment Letter. This is due to the Company’s, and its publicly-traded subsidiaries’,
current engagement in their reporting processes for the third quarter of 2023. We expect to file our response letter within an additional
eight calendar day period following the initial due date, i.e., by Thursday, November 30, 2023.

We appreciate your attention to this letter.
Should you wish to discuss this letter or the Comment Letter at any time, please do not hesitate to contact our legal counsel, Meitar
Law Offices (Mike Rimon, Adv. at 011-972-3-610-3621 or Jonathan M. Nathan, Adv. at 011-972-52-312-5574).

    Sincerely,

    /s/ Asaf Berenstin

    Asaf Berenstin

    Chief Financial Officer

    Formula Systems (1985) Ltd.

    cc:
    Megan Akst

    Kathleen Collins

    (Securities and Exchange Commission)

    Mike Rimon, Adv.

    Jonathan M. Nathan, Adv.

    (Meitar Law Offices)