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CORRESP Filing

Pluri Inc.
Date: May 21, 2025 · CIK: 0001158780 · Accession: 0001213900-25-046215

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File numbers found in text: 001-31392

Date
May 21, 2025
Author
By
Form
CORRESP
Company
Pluri Inc.

Letter

Via EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Life Sciences 100 F Street, NE Washington, DC 20549 Re: Pluri Inc. (the "Company") Preliminary Proxy Statement on Schedule 14A Filed March 14, 2025 File No. 001-31392

Dear Ms. Gama and Mr. Buchmiller,

The purpose of this letter is to respond to the oral comment provided to us by the staff of the U.S. Securities and Exchange Commission, regarding the above-mentioned Preliminary Proxy Statement on Schedule 14A (the "Proxy Statement").

The Company's acquisition of Kokomodo Ltd., as well as the private placement transaction, were approved by the Company's Board of Directors and were memorialized in definitive binding agreements in January 2025, prior to any interested party or director becoming an interested party or director. Therefore, the aforementioned Company transactions complied with Nasdaq Rule 5635(a). In addition, we confirmed this analysis with Nasdaq on a named basis, and Nasdaq agreed with our conclusion that the transactions were compliant with Nasdaq Rule 5635(a).

We thank you for your prompt attention to this letter and look forward to hearing from you at your earliest convenience. If you have any questions or require additional information, please contact our attorneys Ron Ben-Bassat, Esq. at (212) 660-5003, or Howard Berkenblit, Esq. at (617) 338 2979, each of Sullivan & Worcester LLP.

Sincerely,
pluri INC .

Show Raw Text
CORRESP
 1
 filename1.htm

 PLURI
INC.

 Matam Advanced Technology Park

 Building No. 5

 Haifa, 3508409, Israel

 May 21, 2025

 Via EDGAR

 Doris Stacey Gama

 Tim Buchmiller

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Life Sciences

 100 F Street, NE

 Washington, DC 20549

 Re:
 Pluri Inc. (the "Company")
Preliminary Proxy Statement on Schedule 14A
Filed March 14, 2025
File No. 001-31392

 Dear Ms. Gama and Mr. Buchmiller,

 The purpose of this letter is to respond to the
oral comment provided to us by the staff of the U.S. Securities and Exchange Commission, regarding the above-mentioned Preliminary Proxy
Statement on Schedule 14A (the "Proxy Statement").

 The Company's acquisition of Kokomodo Ltd.,
as well as the private placement transaction, were approved by the Company's Board of Directors and were memorialized in definitive
binding agreements in January 2025, prior to any interested party or director becoming an interested party or director. Therefore, the
aforementioned Company transactions complied with Nasdaq Rule 5635(a). In addition, we confirmed this analysis with Nasdaq on a named
basis, and Nasdaq agreed with our conclusion that the transactions were compliant with Nasdaq Rule 5635(a).

 We thank you for your prompt attention to this
letter and look forward to hearing from you at your earliest convenience. If you have any questions or require additional information,
please contact our attorneys Ron Ben-Bassat, Esq. at (212) 660-5003, or Howard Berkenblit, Esq. at (617) 338 2979, each of Sullivan &
Worcester LLP.

 Sincerely,

 pluri INC .

 By:
 /s/ Liat Zalts

 Chief Financial Officer