SecProbe.io

November 27, 2019
Dan Sztybel
Chief Executive Officer
Save Foods, Inc.
Habarzel 7
Tel Aviv, Israel 6971011
Re:Save Foods, Inc.
Amendment No. 1 to Form 10
Filed November 14, 2019
File No. 000-56100
Dear Mr. Sztybel:
            We have reviewed your filing 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.
Amendment to Form 10 filed November 14, 2019
Our Business, page 6
1.We note your response to our prior comment 1 and reissue the comment in part.  We note
you indicate you have initiated the registration process for regulatory approvals in the
United States.  Please expand to further explain what actions you have taken in the
registration process, including whether or not you have submitted anything to the
regulatory agencies you reference.
Description of Registrant's Securities to be Registered, page 41
2.We note your response to our prior comment 9 and re-issue in part.  We note your revised
disclosure that indicates the choice of forum does not apply to suits brought to enforce a
duty or liability created by the Securities Act or Exchange Act.  If this provision does not
apply to actions arising under the Securities Act or Exchange Act, disclose that in this

 FirstName LastNameDan Sztybel
 Comapany NameSave Foods, Inc.
 November 27, 2019 Page 2
 FirstName LastName
Dan Sztybel
Save Foods, Inc.
November 27, 2019
Page 2
section, and please also ensure that the the exclusive forum provision in the governing
document states this clearly or tell us how you will inform investors in future filings that
the provision does not apply to actions arising under the Securities Act or Exchange Act.
December 31, 2018 Financial Statements, page F-1
3.Please note that the par value of your shares should increase inversely in a reverse stock
split so that the number of shares decreases by a multiple of 15, yet the par value increases
by the same multiple so that the value of the stock remains unchanged.  Please revise
accordingly.
Notes to Consolidated Financial Statements
Note 18, page F-29
4.We note your response to our prior comment 7.  We also note your disclosure that on May
26, 2019 the Company amended and restated its Certificate of Incorporation to effect a 15
to 1 reverse split of the company's outstanding stock.  Please file your amended and
restated Certificate of Incorporation or advise.
            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.
            You may contact Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301
if you have questions regarding comments on the financial statements and related matters.
Please contact Susan Block at 202-551-3210 or John Dana Brown at 202-551-3859 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences