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    June
    28, 2023

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    FOIA
    CONFIDENTIAL TREATMENT REQUEST

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    Silicon
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    Confidential
    Treatment Requested by

    Houston
    Singapore

    ODDITY
    Tech Ltd.

    London
    Tel
    Aviv

    8
    Haharash Street

    Los
    Angeles
    Tokyo

    Tel
    Aviv-Jaffa, 6761304, Israel

    Madrid
    Washington,
    D.C.

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549-6010

Attention:             Alan Campbell

Joshua Gorsky

Mary Mast

Sasha Parikh

 Re: ODDITY Tech Ltd.

Registration Statement on Form F-1

Filed June 23, 2023

File No. 333-272890

Ladies
and Gentlemen:

On behalf of our client, ODDITY
Tech Ltd. (the “Company”), we are providing this letter in response to comment 10 (the “Comment”)
received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
by letter, dated May 27, 2022, regarding the above-referenced Registration Statement on Form F-1 (the “Registration
Statement”). Unless otherwise indicated, capitalized terms used herein will have the meanings assigned to them in the Registration
Statement.

The Company requests confidential
treatment for certain portions of this letter pursuant to 17 C.F.R. §200.83. This letter is accompanied by such request for confidential
treatment because of the commercially sensitive nature of the information discussed herein. A redacted letter will be filed on EDGAR,
omitting the confidential information contained in this letter. The Company respectfully requests that the Commission provide timely notice
to the undersigned before it permits any disclosure of the bracketed and highlighted information contained in this letter.

    June 28, 2023

    Page 2

Estimated Preliminary Price Range

The Company advises the Staff
that, while not yet reflected in the Registration Statement, based on discussions with the Company’s board of directors (the “Board”)
and reflecting input from the lead underwriters for the Company’s proposed initial public offering (“IPO”),
the Company currently anticipates an estimated price range of $[***] to $[***] per share (the “Preliminary Price Range”)
for the Company’s Class A ordinary shares to be sold in the IPO, with a midpoint of the anticipated range of approximately
$[***] per share. The Preliminary IPO Price Range does not reflect the share split that the Company intends to effect prior to the Commission’s
declaration of effectiveness of the Registration Statement. The Company advises the Staff that the final range to be included in a pre-effective
amendment to the Registration Statement, after giving effect to an appropriate share split, will include a price range of no more than
$2.00, if the maximum price is $10.00 per share or less, or 20%, if the maximum price is greater than $10.00 per share, unless otherwise
approved by the Staff.

We confirm on behalf of the
Company that, prior to circulating copies of the preliminary prospectus in connection with the IPO, the Company will file a pre-effective
amendment to the Registration Statement that will include all information, other than information that may be excluded in reliance upon
Rule 430A under the Securities Act of 1933, as amended. Such pre-effective amendment to the Registration Statement will include a
post-split bona fide estimated public offering price range. However, the Company further advises the Staff that, given the volatility
in the public trading markets and uncertainty of the timing of the IPO, the final price range to be included in a pre-effective amendment
to the Registration Statement remains under discussion between the Company and the lead underwriters and will be subject to then-current
market conditions and developments impacting the Company.

Summary of Recent Equity Award Grants and Ordinary
Share Valuations

In response to the Comment,
set forth below is an analysis of all equity awards that have been granted since June 30, 2022 (the “Review Period”).

The Company periodically grants
share options and restricted share unit (“RSU”) awards to certain of its employees, directors and consultants.
Share-based compensation expense related to share-based awards is recognized based on the fair value of the awards granted. As there has
been no public market for the ordinary shares of the Company to date, the estimated fair value of the Company’s ordinary shares
underlying such awards has been determined by the Board as of each grant date, with input from management, consideration of periodic independent
third-party valuations of the ordinary shares, and the Board’s assessment of additional objective and subjective factors that it
believed were relevant at that time, including as applicable:

 · actual and forecasted operating and financial performance of the Company based on management’s estimates;

 · lack of marketability of the Company’s ordinary shares;

[***] Certain information contained in this
letter, marked by brackets, has been omitted and filed separately with the Commission pursuant to 17 C.F.R. §200.83.

 Confidential Treatment Requested by ODDITY Tech Ltd.

    2

    June 28, 2023

    Page 3

 · industry trends and competitive environment;

 · the likelihood and timing of achieving a liquidity event, such as an IPO or the sale of the Company given
prevailing market conditions;

 · overall market conditions, including the prices of businesses engaged in the same or similar lines of
business as the Company having their shares actively traded in the public markets;

 · arm’s length secondary transactions involving the Company’s ordinary shares;

 · overall economic indicators; and

 · the general economic outlook.

The independent third-party
valuations were performed in accordance with the guidance outlined in the ASA Business Valuation Standards of the American Society
of Appraisers and in conformity with the Uniform Standards of Professional Appraisal Practice (the “Standards”).
The Standards identify various available methods for allocating enterprise value across classes and series of share capital to determine
the estimated fair value of ordinary shares at each valuation date. In valuing the Company’s ordinary shares, absent a recent financing
or secondary transaction, the independent third-party valuations determined the enterprise value of the Company using a combination of
the income approach and market approach with input from management, which are described as follows:

 · The income approach measures the value of a business based on the expected stream of benefits or cash
flow derived from the subject company and involves estimating the discounted cash flow of the business.

 · The market approach is based on the premise that a business can be valued relative to comparable transactions
of entire businesses or interests in those businesses. The primary methodologies used under the market approach were the guideline public
companies method (“GPC method”) and the potential initial public offering scenario (the “IPO scenario”).

 o The GPC method estimates enterprise value based on a comparison of the Company to comparable public companies
in a similar line of business and generally applies representative valuation ratios, which relate market prices to selected financial
statistics derived from the comparable companies, to the subject company after consideration of adjustments for financial position, growth,
markets, profitability, reinvestment needs, risk and other factors. The Company’s peer group of companies was selected based on
operational and economic similarities to the Company and factors included, but were not limited to, industry, business model, operations,
geographic presence, financial size and performance, share liquidity and management recommendations regarding the most similar companies.

[***] Certain information contained in this
letter, marked by brackets, has been omitted and filed separately with the Commission pursuant to 17 C.F.R. §200.83.

 Confidential Treatment Requested by ODDITY Tech Ltd.

    3

    June 28, 2023

    Page 4

 o The IPO scenario enterprise value is based on input from management, including expected time to IPO, as
well as available market data related to the IPO market generally and the recent IPOs of similar companies.

In
addition, any recent secondary transactions involving the Company’s ordinary shares were considered. The facts and circumstances
of each transaction were evaluated to determine the extent to which they represented a fair value exchange. Factors considered included
transaction volume, proximity to other transactions, as well as the valuation date, frequency of similar transactions, whether the transactions
occurred between willing and unrelated parties, and whether the transactions involved parties with sufficient access to the Company’s
financial information from which to make an informed decision on price.

The enterprise value was determined,
based on the probability-weighted enterprise values of the above-mentioned income and market approaches. Subsequently, the equity value
was determined by subtracting the net debt from the enterprise value. The determined equity value was then allocated across the Company’s
classes of share capital in order to derive a per share value of the Company’s ordinary shares using an Option Pricing Methodology
(“OPM”) with a probability-weighted time to exit. The OPM uses option theory to value the various classes of
the Company’s securities in light of their respective claims to the Company’s total shareholders’ equity. In particular,
total equity value is allocated to the various share classes based upon their respective claims on a series of call options with strike
prices at various value levels depending upon the liquidation preferences, participation rights, and conversion rights of each class of
equity.

Lastly, a discount for lack
of marketability (“DLOM”) was applied, when appropriate, to reflect the lack of a recognized market for the
Company’s ordinary shares and the fact that a non-controlling equity interest may not be readily transferable. The DLOM was estimated
based on, among other factors, put option models, the nature of the Company’s operations and related risks, and the severity of
the restrictions on liquidity of the Company’s ordinary shares.

For financial reporting purposes,
and as further described below, the Company also retrospectively assessed the fair value of ordinary shares and considered the amount
of time between the date of each third-party valuation report and the grant date to determine whether to use the latest ordinary share
valuation determined pursuant to the methods described above or a straight-line methodology to interpolate the estimated fair value between
two valuation dates. In the cases described below, the Company determined that the straight-line methodology would provide the most reasonable
basis for the valuation of the ordinary share on these interim dates between valuations because there was no single event that occurred
during these periods that resulted in the increase in fair value but rather continued progress consistent with the Company’s financial
targets, as well as the Company’s progress toward a liquidity event.

[***] Certain information contained in this
letter, marked by brackets, has been omitted and filed separately with the Commission pursuant to 17 C.F.R. §200.83.

 Confidential Treatment Requested by ODDITY Tech Ltd.

    4

    June 28, 2023

    Page 5

The following table summarizes
share-based compensation awards granted during the Review Period:

    Grant Date
    Type of Award
    Number of
 Shares
 Underlying
 Equity Awards
 Granted
    Option Exercise
 Price(1)
    Estimated Fair
 Value Per
 Share for
 Financial
 Reporting
 Purposes

    July 31, 2022
    Options
      584
    $ [***]
    $ 368.26

    July 31, 2022
    RSUs
      1,860
      N/A
    $ 368.26

    November 30, 2022
    Options
      6,401
    $ [***]
    $ 364.35

    November 30, 2022
    Options
      3,445
    $ [***]
    $ 364.35

    November 30, 2022
    Options
      898
    $ [***]
    $ 364.35

    November 30, 2022
    Options
      140
    $ [***]
    $ 364.35

    November 30, 2022
    RSUs
      2,730
      N/A
    $ 364.35

    April 4, 2023
    Options
      6,568
    $ [***]
    $ 427.00

    April 4, 2023
    RSUs
      3,046
      N/A
    $ 427.00

    May 12, 2023
    RSUs
      13,941
      N/A
    $ 427.00

    June 22, 2023
    Options
      423,233
    $ [***]
    $ 427.00

    June 22, 2023
    Options
      352
    $ [***]
    $ 427.00

    June 22, 2023
    RSUs
      34,986
      N/A
    $ 427.00

 (1) Variance in exercise prices of options granted on the same dates relate to options granted to
employees based in Israel as opposed to employees based in the United States. Pursuant to Israeli law, options may be granted to employees
with an exercise price per share below fair value; provided, however, that the compensation charge taken by the grantor of the options
be the fair value per share of such grants.

July 2022
Grants

The Company’s management
and Board determined the fair value of the Company’s ordinary shares for financial reporting purposes to be $368.26 per share as
of July 31, 2022 based on a straight-line interpolation between the concluded fair values set forth in a valuation report provided
by an independent third-party valuation firm of the Company’s ordinary shares as of June 30, 2022 (the “June 2022
Valuation”) and as of September 30, 2022 (the “September 2022 Valuation”), each as further
described below, as well as other objective and subjective factors deemed relevant as of the grant date. The Company concluded that use
of the straight-line interpolation was appropriate as it represents the continued growth of the Company’s business and the Company
did not identify any single event that occurred during the period between the two valuation dates that would have caused a material change
in fair value at the date of the grant other than the passage of time.

The June 2022 Valuation
determined the enterprise value of the Company by applying two scenarios: (i) status quo scenario weighted at 60% probability and
(ii) IPO scenario (estimated to potentially occur in 0.5 years) weighted at 40% probability. Under the status quo scenario, the June 2022
Valuation applied the income approach weighted at 70% and the GPC method weighted at 30%. The probability and timing of the IPO scenario
was determined based primarily on input from the Board and management considering, among other things, the initiation of preparations
for a potential IPO, including the engagement of underwriters and other advisors and the submission of a registration in connection with
a potential IPO, as well as the feasibility of completing an IPO and general conditions in the capital markets. Once an enterprise value
(and subsequently the equity value) was determined, the June 2022 Valuation relied on an OPM framework to allocate the Company’s
equity value. Finally, a DLOM of 10% was applied. The June 2022 Valuation concluded that the fair value of the Company’s ordinary
shares as of June 30, 2022 was $433.60 per share and $390.20 per share on a pre-DLOM and post-DLOM basis, respectively.

[***] Certain information contained in this
letter, marked by brackets, has been omitted and filed separately with the Comm