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June 22, 2023
Oran Holtzman
Chief Executive Officer
ODDITY Tech Ltd.
8 Haharash Street
Tel Aviv-Jaffa, 6761304, Israel
Re:ODDITY Tech Ltd.
Amendment No. 8 to Draft Registration Statement on Form F-1
Submitted June 8, 2023
CIK No. 0001907085
Dear Oran Holtzman:
            We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 8 to Draft Registration Statement on Form F-1
Recent Developments
Estimated Selected Preliminary Results for the Three Months Ended June 30, 2023 (unaudited),
page 8
1.With regard to the reconciliation for the three months ended June 30, 2023 of estimated
Operating Income to Adjusted EBITDA, please address the following:
•Tell us why it is appropriate to adjust for Taxes on income as that amount is not
included in either Operating income or Adjusted EBITDA.
•The reconciliation to Adjusted EBITDA should be from the most directly comparable
GAAP measure, which appears to be Net Income. If you are unable to estimate Net
Income, please tell us why the terminology "Adjusted EBITDA" is consistent with

 FirstName LastNameOran Holtzman
 Comapany NameODDITY Tech Ltd.
 June 22, 2023 Page 2
 FirstName LastName
Oran Holtzman
ODDITY Tech Ltd.
June 22, 2023
Page 2
the Non-GAAP C&DI Question 100.05.
Management's Discussion and Analysis
Non-GAAP Financial Measures, page 92
2.We read your response and revised disclosures to our previous comment 1 and continue to
believe that the non-GAAP adjustment for the founders' incentive plan is inconsistent with
the guidance under Question 100.01 of the Non-GAAP Financial Measures Compliance
and Disclosure Interpretation as it is a recurring (i.e. over multiple periods) cash expense
related to growing your business as a result of such incentive bonuses being provided due
to the revenues generated from Spoiled Child. As such, please revise accordingly.
Founder Option Agreements, page 163
3.Please revise your disclosure here to clarify whether each of Mr. Holtzman and Ms.
Holtzman-Erel will be granted option awards for 257,188 Class A ordinary shares or
whether both Mr. Holtzman and Ms. Holtzman-Erel will be granted option awards for
a total of 257,188 Class A ordinary shares to be divided between them.  Please also
disclose the exercise price of the option awards.
Notes to Consolidated Financial Statements for the Three Months Ended March 31, 2023
Note 11: Subsequent Events, page F-45
4.Please disclose the anticipated accounting treatment for the acquisition of Revela Inc.
            You may contact Sasha Parikh at 202-551-3627 or Mary Mast at 202-551-3613 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Joshua Gorsky at 202-551-7836 or Alan Campbell at 202-551-4224 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Alison Haggerty