Correspondence 0001104659-23-003654 from SatixFy Communications Ltd. (SATX, STXYF) (CIK 0001915403)
SatixFy Communications Ltd. (SATX, STXYF) (CIK 0001915403)
Date: Jan. 13, 2023 · CIK: 0001915403 · Accession: 0001104659-23-003654
AI Filing Summary & Sentiment
File numbers found in text: 333-268510
Referenced dates: January 5, 2023
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CORRESP
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filename1.htm
Davis
Polk & Wardwell llp
450
Lexington Avenue
New York, NY 10017
davispolk.com
CONFIDENTIAL
January
13, 2023
Re:
SatixFy Communications Ltd.
Amendment
No. 1 to Registration Statement on Form F-1
Filed
December 16, 2022
File
No. 333-268510
Attention:
Evan Ewing, Jay Ingram
Division
of Corporation Finance
Office
of Manufacturing
U.S.
Securities and Exchange Commission
100
F Street, N.E.
Washington,
DC 20549-3628
Ladies
and Gentlemen:
On
behalf of SatixFy Communications Ltd., a limited liability company organized under the laws of the State of Israel (“SatixFy”,
or the “Company”), we are responding to the comment from the Staff (the “Staff”) of the Securities
and Exchange Commission (the “Commission”) relating to Amendment No. 1 to the Company’s Registration Statement
on Form F-1 filed on December 16, 2022 (the “Registration Statement”) contained in the Staff’s letter dated
January 5, 2023 (the “Comment Letter”). In response to the comment set forth in the Comment Letter, the Company has
amended the Registration Statement and is submitting it together with this response letter (“Amendment No. 2”).
Set
forth below are the Company’s responses to the Staff’s comment. For convenience, the Staff’s comment is repeated below
in italics, followed by the Company’s response to the comment. Capitalized terms used but not defined within this letter have the
meanings ascribed to them in the revised Registration Statement.
Registration
Statement on Form F-1
Aggregate
Compensation of Directors and Executive Officers, page 133
1. Please
update your compensation disclosure to reflect the fiscal year ended December 31, 2022.
· Response:
The Company respectfully acknowledges the Staff’s comment and has revised page
134 of Amendment No. 2.
Please
do not hesitate to contact me at (212) 450-4111, (212) 701-5111 (fax) or michael.kaplan@davispolk.com if you have any questions regarding
the foregoing or if I can provide any additional information.
Very truly yours,
/s/ Michael Kaplan
Michael Kaplan
cc:
Yoav
Leibovitch, Chairman of the Board of Directors
Oren
Harari, Interim Chief Financial Officer
Brian
Wolfe
Davis
Polk & Wardwell LLP
Tomer
Fromovich
Ziv
Haft Certified Public Accountants (Isr.), a member firm of BDO International Limited