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CORRESP
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CORRESP

 Wilson Sonsini Goodrich & Rosati

Professional Corporation

 650 Page
Mill Road

 Palo Alto, California 94304-1050

O: 650.493.9300

F: 650.493.6811

 September 14, 2020

Via EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549

Attention:

Jan Woo

Jeffrey Kauten

Kathleen Collins

Joyce Sweeney

Re:
 JFrog Ltd.

Registration Statement on Form S-1

Registration Statement No. 333-248271

Ladies and Gentlemen:

 On behalf of our client,
JFrog Ltd. (“JFrog” or the “Company”), we submit this letter to assist the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in its review of the
Company’s Registration Statement on Form S-1 (File No. 333-248271) (the “Registration Statement”). This letter supplements the Company’s
letters filed with the Commission on August 31, 2020 and September 4, 2020 (the “Prior Letters”) relating to the Registration Statement.

The Company supplementally advises the Staff that Amendment No. 2 to the Registration Statement, as filed with the Commission on the date
hereof (the “Amendment No. 2”), reflects a preliminary price range of $39.00 to $41.00 per share (the “Preliminary Price Range”), resulting in a midpoint of the Preliminary Price Range of $40.00
per share (the “Midpoint Price”). The Preliminary Price Range represents an increase from the estimated preliminary price range of $33.00 to $37.00 per share, as previously set forth in Amendment No. 1 to the Registration
Statement, as filed with the Commission on September 8, 2020.

 The Company further advises the Staff that it has re-assessed the fair
value of the Company’s ordinary shares in connection with all equity awards granted subsequent to June 30, 2020 using a straight-line methodology from the June 2020 third party valuation (as described in the Prior Letters) through the
Midpoint Price. Set forth below is a summary of the Company’s equity awards granted from June 30, 2020 to the date hereof, including the re-assessed fair value of the underlying ordinary shares for
reference:

AUSTIN        BEIJING        BOSTON
   BRUSSELS        HONG KONG        LONDON        LOS
ANGELES        NEW YORK         PALO ALTO

 SAN
DIEGO        SAN FRANCISCO        SEATTLE        SHANGHAI        WASHINGTON,
DC        WILMINGTON, DE

 Securities and Exchange Commission

September 14, 2020

  Page
 2

 Event

Event Date

Number of
Awards Granted

Exercise Price

Fair Value per
Share for Financial
Reporting

 Third-party Valuation

June 30, 2020

—

—

$
20.61

 Third-party Valuation

July 29, 2020

—

—

$
23.00

 Option Grants

July 29, 2020

1,343,355

$
23.00

$
27.82

 RSU Award

August 30, 2020

667,595

—

$
35.77

 Option Grants

September 3, 2020

160,000

$
35.00

$
36.77

 The Company has revised the subsequent events footnote in Amendment No. 2 to reflect the estimated
aggregate amount of share-based compensation expense for all equity awards granted subsequent to June 30, 2020.

 * * * *

Please contact me at (650) 565-3765 or aspinner@wsgr.com, or my colleague, Jeffrey D. Saper, at (650) 320-4626 or jsaper@wsgr.com if you have any questions regarding the foregoing. Thank you for your assistance.

Sincerely,

WILSON SONSINI GOODRICH & ROSATI

Professional Corporation

 /s/ Allison B. Spinner

Allison B. Spinner

 Enclosures

cc:
 Shlomi Ben Haim, JFrog Ltd.

Jacob Shulman, JFrog Ltd.

 Eyal
Ben David, JFrog Ltd.

 Jeffrey J. Saper, Wilson Sonsini Goodrich & Rosati, P.C.

 Securities and Exchange Commission

September 14, 2020

  Page
 3

 Steven V. Bernard, Wilson Sonsini Goodrich & Rosati, P.C.

Mark V. Roeder, Latham & Watkins LLP

Brian D. Paulson, Latham & Watkins LLP

Joshua G. Kiernan, Latham & Watkins LLP

Yair Nagar, Kost Forer Gabbay & Kasierer-Ernst & Young Israel