SecProbe.io

January 30, 2019
Yaacov Michlin
Chief Executive Officer
Brainsway Ltd.
19 Hartum Street
Bynet Building, 3rd Floor
Har HaHotzvim
Jerusalem, 9777518, Israel
Re:Brainsway Ltd.
Registration Statement on Form F-1
Filed November 16, 2018
File No. 333-229233
Dear Mr. Michlin:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form F-1 filed January 14, 2019
Preliminary Results for Fourth Quarter of 2018, page 6
1.Please tell us why you believe it is appropriate to present only revenue from your fourth
quarter operating results without also presenting appropriate measures of net income
(loss).  See Regulation S-K Item 10(b)(2).
Use of Proceeds, page 64
2.As requested by prior comment 6, for indebtedness incurred within the past year, disclose
the uses to which the proceeds of such indebtedness were put.

 FirstName LastNameYaacov Michlin
 Comapany NameBrainsway Ltd.
 January 30, 2019 Page 2
 FirstName LastName
Yaacov Michlin
Brainsway Ltd.
January 30, 2019
Page 2
Compensation of Senior Management and Directors, page 125
3.Please update your senior management and director compensation disclosure to include
the registrant´s last completed fiscal year.
Other Activities and Relationships, page 178
4.We continue to note your disclosure that the underwriters and certain of their
affiliates may have performed various investment banking and financial advisory services
for you and your affiliates.  As requested by prior comment 14, please clarify which
underwriters and affiliates you are referring to and the nature and terms of such
relationships.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Michael Fay at (202) 551-3812 or Brian Cascio, Accounting Branch
Chief, at (202) 551-3676 if you have questions regarding comments on the financial statements
and related matters.  Please contact Tim Buchmiller at (202) 551-3635 or Geoff Kruczek, Special
Counsel, at (202) 551-3641 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc:       Cheryl Reicin, Esq.