SecProbe.io

September 11, 2025
Eliran Glazer
Chief Financial Officer
monday.com Ltd.
6 Yitzhak Sadeh Street
Tel Aviv, 6777506 Israel
Re:monday.com Ltd.
Form 20-F for the Year Ended December 31, 2024
File No. 001-40461
Dear Eliran Glazer:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for the Year Ended December 31, 2024
Operating Results
Comparison of the Years Ended December 31, 2024 and 2023, page 60
1.Please revise to provide a more substantive analysis of the reasons for changes in
revenue during the periods presented. Your discussion should address the impact of
changes in pricing, new or expanded product lines, and to the extent possible, quantify
increases driven by existing customers separate from increases attributable to new
customers. We note, for example, that the Q4 2024 and Q2 2025 shareholder letters
provided on your website include metrics about customer growth associated with your
CRM, service and dev products that provide additional insights not addressed in
MD&A. Similarly, in your February 10, 2025 earnings call, management
quantified the impact of pricing on 2024 results and provided an estimate of expected
future pricing impacts but neither are included in your MD&A for the year ended
December 31, 2024. Refer to Item 303 of Regulation S-K.

September 11, 2025
Page 2
Liquidity and Capital Resources, page 64
2.We note that you have a significant amount of cash on hand as of December 31, 2024.
Please revise to provide a more substantive discussion of your material cash
requirements from known and other obligations both in the short-term and separately
in the long-term (beyond the next 12 months). As part of this analysis, identify any
known trends, demands, commitments, events or uncertainties that are reasonably
likely to materially impact your liquidity and capital resources. For example, we note
from your Q4 2024 investor presentation that your future plans include an expansion
of your core work product lines. Additionally, in your August 11, 2025 earnings call,
management discussed investing in mondayDB. Your revised disclosures should
address the timeline and expected cost of any known or anticipated investments along
with the anticipated impact on your capital resources and liquidity.
Consolidated Financial Statements
Note 16. Segment Reporting, page F-48
3.We note your disclosure indicating that you manage your business on the basis of one
reportable segment and unit. Based upon comments made by management during your
February 10, 2025 earnings call, it appears that discrete financial information below
the consolidated level is both available to and reviewed by management. Please tell us
how you considered ASC 280-10-50 in determining your operating and reportable
segments. To the extent that you have aggregated multiple operating segments into a
single reportable segment, please also tell us your basis for doing so.
4.Please refer to ASC 280-10-50-40 and tell us how you considered disclosing revenues
from external customers for each of your four main products: work management,
CRM, dev and service. We note a recent announcement in your Q2 2025 shareholder
letter that the CRM product reached $100 million in ARR. As such, it appears that
there is sufficient financial information available to report revenues from external
customers by product.
            In closing, 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.
            Please contact Lisa Etheredge at 202-551-3424 or Robert Littlepage at 202-551-3361
with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology