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 July 15, 2025

Amos Cohen
Chief Financial Officer
Intercure Ltd.
85 Medinat ha-Yehudim Street
Herzliya, 4676670, Israel

 Re: Intercure Ltd.
 Form 20-F for the Fiscal Year Ended December 31, 2024
 Filed May 1, 2025
 File No. 001-40614
Dear Amos Cohen:

 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 Fiscal Year Ended December 31, 2024
Non-IFRS Financial Measures, page 3

1. We note your use of Adjusted EBITDA, which represents EBITDA adjusted
for
 changes in the fair value of inventory, share-based payment expense,
impairment
 losses (and gains) on financial assets, and other expenses (or income).
Please quantify
 the components of the adjustment for "other expenses, net" and explain
your
 consideration of Item 10(e) of Regulation S-K in excluding these amounts
from your
 Non-IFRS measure. In this regard, based on your reconciliation on page
74, "other
 expenses, net" appears to represent the most significant adjustment in
arriving at
 Adjusted EBITDA.
 July 15, 2025
Page 2
Item 5. Operating and Financial Review and Prospects
Results of Operations, page 74

2. Please tell us your consideration of providing disaggregated revenue
disclosure in
 future filings by brand and/or type of product. In this regard, we refer
to your list of
 branded pharmaceutical-grade products on page 48.
Consolidated Statements of Profit or Loss and Other Comprehensive Income, page
F-5

3. Please explain how your Unrealized changes to fair value adjustments of
biological
 assets of NIS 6.5 million and Loss from fair value changes realized in
the current year
 of NIS 11.8 million were calculated. Please also explain how these
amounts correlate
 to the NIS 1.6 million change in fair value less selling costs as
disclosed on page F-29.

 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 Frank Wyman at 202-551-3660 or Angela Connell at
202-551-3426
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
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