SecProbe.io

January 22, 2026
Jacob (Kobi) Marinka
Chief Executive Officer
Arbe Robotics Ltd.
HaHashmonaim St. 107
Tel Aviv-Yafo
Israel
Re:Arbe Robotics Ltd.
Registration Statement on Form F-3
Filed January 20, 2026
File No. 333-292838
Dear Jacob (Kobi) Marinka:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Jan Woo at 202-551-3453 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Shay Dayan

CORRESP
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 filename1.htm

 Arbe Robotics Ltd.

 HaHashmonaim St. 107

 Tel Aviv-Yafo

 Israel

 January 27, 2026

 VIA EDGAR

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street N.E.

 Washington, D.C. 20549

 Re:
 Arbe Robotics Ltd.

 Registration Statement on Form F-3

 File No. 333- 292838

 Ladies and Gentleman:

 Pursuant to Rule 461 under the
Securities Act of 1933, as amended, Arbe Robotics Ltd. hereby requests acceleration of effectiveness of the above referenced Registration
Statement on Form F-3 so that it will become effective at 12:00 p.m. EST on January 29, 2026, or as soon as thereafter practicable.

 Very truly yours,

 /s/ Jacob (Kobi) Marinka

 Jacob (Kobi) Marinka

 Chief Executive Officer and Director

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 Arbe Robotics Ltd.

 HaHashmonaim St. 107

 Tel Aviv-Yafo

 Israel

 June 11, 2025

 VIA EDGAR

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street N.E.

 Washington, D.C. 20549

 Re:
 Arbe Robotics Ltd.

 Registration Statement on Form F-3

 File No. 333-287805

 Ladies and Gentleman:

 Pursuant to Rule 461 under the
Securities Act of 1933, as amended, Arbe Robotics Ltd. hereby requests acceleration of effectiveness of the above referenced Registration
Statement on Form F-3 so that it will become effective at 4:00 p.m. EST on June 13, 2025, or as soon as thereafter practicable.

 Very truly yours,

 /s/ Jacob (Kobi) Marinka

 Jacob (Kobi) Marinka

 Chief Executive Officer and Director

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 11, 2025

Jacob Marinka
Chief Executive Officer
Arbe Robotics Ltd.
107 HaHashmonaim Street
Tel Aviv-Yafo, Israel

 Re: Arbe Robotics Ltd.
 Registration Statement on Form F-3
 Filed June 5, 2025
 File No. 333-287805
Dear Jacob Marinka:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rule 461 regarding requests for acceleration. 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 Marion Graham at 202-551-6521 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Jonathan Deblinger
</TEXT>
</DOCUMENT>

CORRESP
1
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ARBE ROBOTICS LTD.

HaHashmonaim St. 107

Tel Aviv-Yafo, Israel

June 26, 2024

By EDGAR

Division of Corporation Finance

Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549

    Re:
    Arbe Robotics Ltd.

    Registration Statement on Form F-3

    Filed June 18, 2024

    File No. 333-280319

Ladies and Gentlemen:

Pursuant to Rule 461, Arbe Robotics Ltd. requests
acceleration of effectiveness of the above referenced registration statement on Form F-3 to 4:30 P.M. on Thursday, June 27, 2024, or as
soon thereafter as possible.

    Very truly yours,

    /s/ Jacob (Kobi) Marinka

    Jacob (Kobi) Marinka, Chief Executive Officer

United States securities and exchange commission logo
June 25, 2024
Jacob Marinka
Chief Executive Officer
Arbe Robotics Ltd.
HaHashmonaim St. 107
Tel Aviv-Yafo, Israel
Re:Arbe Robotics Ltd.
Registration Statement on Form F-3
Filed June 18, 2024
File No. 333-280319
Dear Jacob Marinka:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rule 461 regarding requests for acceleration. 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 Marion Graham at 202-551-6521 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology

United States securities and exchange commission logo
May 17, 2023
Jacob (Kobi) Marinka
Chief Executive Officer
Arbe Robotics Ltd.
107 HaHashmonaim St.
Tel Aviv-Yafo, Israel
Re:Arbe Robotics Ltd.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed March 22, 2023
File No. 001-40884
Dear Jacob (Kobi) Marinka:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
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Arbe Robotics Ltd.

HaHashmonaim St. 107

Tel Aviv-Yafo

Israel

May 9, 2023

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

Washington, DC 20549

    Re:

    Arbe Robotics Ltd.

    Form 20-F for the year ended December 31, 2022

    Filed March 22,2023July 30, 2021

    File No. 001-40884

Ladies and Gentlemen:

Arbe Robotics Ltd. (the “Company”)
hereby transmits its response to the letter received from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”), dated April 26, 2023. For ease of reference, we have repeated the Commission’s comment in this response
letter. An amendment to the Company’s 20-F is being submitted publicly to accompany this response letter.

Form 20-F for the Fiscal Year Ended December 31, 2022

Item 15. Controls and Procedures, page 85

 1. Please file an amended Form 20-F to include management’s
report on internal control over financial reporting. Refer to Item 15(b) of Form 20-F and Question 2 of the Frequently Asked Questions
for Exemptive Order on Management’s Report on Internal Control over Financial Reporting available at: https://www.sec.gov/divisions/corpfin/faq012105.htm.

Response: Item 15 has been amended to include
disclosure Management’s Report on Internal Control over Financial Reporting and its conclusion that its disclosure control over
financial reporting were effective.

    Very truly yours.

    /s/ Jacob (Kobi) Marinka

    Jacob (Kobi) Marinka, CEO

United States securities and exchange commission logo
April 26, 2023
Jacob (Kobi) Marinka
Chief Executive Officer
Arbe Robotics Ltd.
107 HaHashmonaim St.
Tel Aviv-Yafo, Israel
Re:Arbe Robotics Ltd.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed March 22, 2023
File No. 001-40884
Dear Jacob (Kobi) Marinka:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 15. Controls and Procedures, page 85
1.Please file an amended Form 20-F to include management's report on internal control over
financial reporting.  Refer to Item 15(b) of Form 20-F and Question 2 of the Frequently
Asked Questions for Exemptive Order on Management's Report on Internal Control over
Financial Reporting available at: https://www.sec.gov/divisions/corpfin/faq012105.htm.

            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.

 FirstName LastNameJacob (Kobi) Marinka
 Comapany NameArbe Robotics Ltd.
 April 26, 2023 Page 2
 FirstName LastName
Jacob (Kobi) Marinka
Arbe Robotics Ltd.
April 26, 2023
Page 2
            You may contact Joyce Sweeney, Senior Staff Accountant, at 202-551-3449 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 with any questions.

Sincerely,
Division of Corporation Finance
Office of Technology

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Arbe Robotics Ltd.

HaHashmonaim St. 107

Tel Aviv-Yafo

Israel

February 22, 2023

VIA EDGAR

Division of Corporation Finance

Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549

    Re:
    Arbe Robotics Ltd.

    Registration Statement on Form F-3

    File No. 333-269235

Ladies and Gentlemen:

Pursuant to Rule 461 under the
Securities Act of 1933, as amended, Arbe Robotics Ltd. hereby requests acceleration of effectiveness of the above referenced Registration
Statement on Form F-3 so that it will become effective at 10:00 A.M., EST on February 24, 2023, or as soon as thereafter practicable.

    Very truly yours,

    /s/  Jacob (Kobi) Marinka

    Jacob (Kobi) Marinka

    Chief Executive Officer and Director

United States securities and exchange commission logo
January 23, 2023
Maya Bar-On
General Counsel
Arbe Robotics Ltd.
HaHashmonaim St. 107
Tel Aviv-Yafo
Israel
Re:Arbe Robotics Ltd.
Registration Statement on Form F-3
Filed January 13, 2023
File No. 333-269235
Dear Maya Bar-On:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Charli Gibbs-Tabler, Staff Attorney, at 202-551-6388 or Joshua Shainess,
Legal Branch Chief, at 202-551-7951 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Asher S. Levitsky, P.C.

CORRESP
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ARBE ROBOTICS LTD.

HaHashmonaim St. 107

Tel Aviv-Yafo

Israel

October 29, 2021

By EDGAR

Division of Corporation Finance

Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549

    Re:
    Arbe Robotics Ltd.

    Amendment No. 1 to Registration Statement on Form F-1

    Filed October 29, 2021

    File No. 333-259757

Ladies and Gentlemen:

Pursuant to Rule 461, Arbe Robotics Ltd. requests
acceleration of effectiveness of the above referenced Registration Statement to 4:30 P.M. on Tuesday, November 2, 2021, or as soon thereafter
as possible.

    Very truly yours,

    /s/ Jacob (Kobi) Marinka

    Jacob (Kobi) Marinka,

    Chief Executive Officer

United States securities and exchange commission logo
September 29, 2021
Kobi Marenko
Chief Executive Officer
Arbe Robotics Ltd.
HaHashmonaim St. 107
Tel Aviv-Yafo, Israel
Re:Arbe Robotics Ltd.
Registration Statement on Form F-1
Filed September 24, 2021
File No. 333-259757
Dear Mr. Marenko:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rule 461 regarding requests for acceleration.  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 Jeff Kauten, Staff Attorney, at (202) 551-3447, or in his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453, with any questions.  If you require further
assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Asher Levitsky, Esq.

CORRESP
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Arbe Robotics Ltd.

HaHashmonaim St. 107

Tel Aviv-Yafo, Israel

September 15, 2021

VIA EDGAR AND E-MAIL

Division of Corporation Finance

Office of Technology

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-6010

Attention:	Matthew Crispino

 Re: Arbe Robotics Ltd.

Amendment No. 4 to Registration Statement on Form F-4

CIK No. 0001861841

File No. 333-257250

Ladies and Gentlemen:

In accordance with Rule 461
of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby request acceleration of the
effective date of the Registration Statement on Form F-4, as amended (the “Registration Statement”) of Arbe
Robotics Ltd. (the “Company”). We respectfully request that the Registration Statement become effective as of
4:00 p.m., Eastern Time, on September 17, 2021, or as soon as practicable thereafter. Once the Registration Statement has been declared
effective, please orally confirm that event with our counsel, DLA Piper LLP, by calling Jon Venick at (212) 335-4651.

Thank you for your assistance in this matter.

[signature page follows]

    Very truly yours,

    Arbe Robotics Ltd.

    By:
    /s/ Jacob (Kobi) Marinka

    Name: Jacob (Kobi) Marinka

    Title: Chief Executive Officer

Cc:	(via email)

Jon Venick, DLA Piper LLP

Danny Klein, Arbe Robotics Ltd.

Shay Dayan, Erdinast, Ben
Nathan, Toledano & Co.

E. Scott Crist, Industrial
Tech Acquisitions, Inc.

Asher S. Levitsky, Ellenoff Grossman & Schole
LLP

CORRESP
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    DLA
    Piper LLP (US)

    1251
    Avenue of the Americas

    27th
    Floor

    New
    York, New York 10020-1104

    www.dlapiper.com

    Jon
    Venick

    Jon.Venick@dlapiper.com

    T
    212.335.4651

    F
    917.778.8651

August
16, 2021

Division
of Corporation Finance

Office
of Technology

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549-6010

    Attention:
    Brittany Ebertt

    Christine Dietz

    Jan Woo

    Matthew Crispino

    Re:
    Arbe Robotics Ltd.

    Amendment No. 1 to Registration Statement on Form F-4

    Filed July 30, 2021

    File No. 333-257250

Dear
Mr. Crispino:

On
behalf of Arbe Robotics Ltd. (the “Company”), set forth below are the Company’s responses to the comments of
the Staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”)
relating to the Company’s Amendment No. 1 to Registration Statement on Form F-4 (“Amendment No. 1”). An electronic
version of the amended Registration Statement (“Amendment No. 2”) has been concurrently submitted with the Commission
through its EDGAR system. The enclosed copy of Amendment No. 2 has been marked to reflect changes made to the Registration Statement.

Set
forth below are the responses of the Company to the comments of the Staff’s letter to the Company, dated August 12, 2021, relating
to Amendment No. 1. For convenience of reference, the text of the comments in the Staff’s letter has been reproduced in bold and
italics herein. The Company has also provided its response immediately after each numbered comment. We have included page numbers to
refer to the location in Amendment No. 2 where the amended language addressing a particular comment appears. Capitalized terms used but
not otherwise defined herein have the meanings assigned to such terms in Amendment No. 2.

Proposal
No. 1 - The Business Combination Proposal

The
ITAC Board of Directors Reasons for the Merger, page 96

    1.
    We
    note your revised disclosure in response to prior comment 10 that ITAC evaluated and benchmarked Arbe’s operating metrics against
    its peers in the auto technology sectors and that management concluded that Arbe compared favorably on all key operating metrics.
    Please disclose the peer companies that were evaluated, the specific measures that were considered, and a discussion of why management
    believed that Arbe compared favorably.

Response:
In response to the comment from the Staff, the disclosure under “The ITAC Board of Directors’ Reasons for the Merger”
on page 97 has been expended to identity the sectors that were considered, the companies
in each sector and a description of the metrics considers and the reasons management believed compared favorably.

August
16, 2021

Page
Two

U.S.
Federal Income Tax Considerations of the Merger, page 123

    2.
    We
    note your response to prior comment 11; however, if your “intention” that the merger qualify as a “reorganization”
    under Section 368(a) of the Tax Code is too uncertain to be supported by a tax opinion, you should remove this representation as
    it could be confusing to shareholders.

Response:
In response to the comment from the Staff, the language in Amendment No. 2 has been changed to eliminate the reference to the “intention”
and to recognize the uncertainties. The agreement was structured to accommodate the parties’ business objectives entering this deal including
allowing a tax-free shares exchange for the shareholders. However, since there is currently not sufficient authority from the Internal
Revenue Service that is factually on point with this transaction regarding satisfaction of all of the requirements in the United States
law allowing such tax-free treatment, ITAC and the Company can provide no assurance that a tax-free treatment will be provided for the
exchanging stockholders.

Unaudited
Pro Forma Condensed Combined Financial Information, page 191

    3.
    We
    note your response to prior comment 12. Please revise to include a footnote to the tabular disclosure on page 193 clarifying that
    the total number of shares outstanding at closing includes the 3,312,633 ordinary shares that will be issued upon conversion of the
    Advanced Amount convertible loan.

Response:
In response to the comment from the Staff, a footnote has been added to disclose the 3,312,633 ordinary shares (after the
recapitalization) issued or to be issued subsequent to December 31, 2020 and prior to the closing, including primarily the shares to
be issued upon conversion of the convertible loan.

Adjustments
to Unaudited Pro Forma Condensed Combined Financial Information, page 200

    4.
    We
    note the revised disclosure in response to prior comment 15. Please further revise to remove the references to directly attributable,
    factually supportable and expected to have a continuing impact as they are no longer included in Article 11.

Response:
In response to the comment from the Staff, the Company has deleted the reference to “directly attributable, factually supportable
and expected to have a continuing impact” in the first paragraph of this note. The deletion of this language does not affect the
pro forma financial information presented in the prospectus.

August
16, 2021

Page
Three

Any
comments or questions regarding the foregoing should be directed to the undersigned at 212-335-4651. Thank you in advance for your cooperation
in connection with this matter.

Sincerely,

Jon
Venick

JV:

Cc:
(via email)

Jacob
(Kobi) Marinka, Arbe Robotics Ltd.

Danny
Klein, Arbe Robotics Ltd.

E.
Scott Crist, Industrial Tech Acquisitions, Inc.

Asher
S. Levitsky, Ellenoff Grossman & Schole LLP

Shay
Dayan, Erdinast, Ben Nathan, Toledano & Co.

United States securities and exchange commission logo
August 12, 2021
Jacob (Kobi) Marinka
Chief Executive Officer and Director
Arbe Robotics Ltd.
HaHashmonaim St. 107
Tel Aviv-Yafo
Israel
Re:Arbe Robotics Ltd.
Amendment No. 1 to Registration Statement on Form F-4
Filed July 30, 2021
File No. 333-257250
Dear Mr. Marinka:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our July 21, 2021 letter.
Amendment No. 1 to Form F-4 filed July 30, 2021
Proposal No. 1 - The Business Combination Proposal
The ITAC Board of Directors Reasons for the Merger, page 96
1.We note your revised disclosure in response to prior comment 10 that ITAC evaluated and
benchmarked Arbe's operating metrics against its peers in the auto technology sectors and
that management concluded that Arbe compared favorably on all key operating metrics.
Please disclose the peer companies that were evaluated, the specific measures that were
considered, and a discussion of why management believed that Arbe compared favorably.

 FirstName LastNameJacob (Kobi) Marinka
 Comapany NameArbe Robotics Ltd.
 August 12, 2021 Page 2
 FirstName LastName
Jacob (Kobi) Marinka
Arbe Robotics Ltd.
August 12, 2021
Page 2
U.S. Federal Income Tax Considerations of the Merger, page 123
2.We note your response to prior comment 11; however, if your "intention" that the merger
qualify as a "reorganization" under Section 368(a) of the Tax Code is too uncertain to be
supported by a tax opinion, you should remove this representation as it could be confusing
to shareholders.
Unaudited Pro Forma Condensed Combined Financial Information, page 191
3.We note your response to prior comment 12.  Please revise to include a footnote to the
tabular disclosure on page 193 clarifying that the total number of shares outstanding at
closing includes the 3,312,633 ordinary shares that will be issued upon conversion of the
Advanced Amount convertible loan.
3. Adjustments to Unaudited Pro Forma Condensed Combined Financial Information, page 200
4.We note the revised disclosure in response to prior comment 15.  Please further revise to
remove the references to directly attributable, factually supportable and expected to have a
continuing impact as they are no longer included in Article 11.
            You may contact Brittany Ebbertt, Senior Staff Accountant, at (202) 551-3572
or Christine Dietz Senior Staff Accountant at (202) 551-3408 if you have questions
regarding comments on the financial statements and related matters. Please contact Matthew
Crispino, Staff Attorney, at (202) 551-3456 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Asher S. Levitsky

CORRESP
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    DLA Piper LLP (US)

    1251 Avenue of the Americas

    27th Floor

    New York, New York 10020-1104

    www.dlapiper.com

    Jon Venick

    Jon.Venick@dlapiper.com

    T 212.335.4651

    F 917.778.8651

July 30, 2021

Division of Corporation Finance

Office of Technology

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549-6010

 Attention: Brittany Ebertt

Christine Dietz

Jan Woo

Matthew Crispino

 Re: Arbe Robotics Ltd.

Registration Statement on Form F-4

Filed June 21, 2021

File No. 333-257250

Dear Mr. Crispino:

On behalf of Arbe Robotics Ltd. (the “Company”),
set forth below are the Company’s responses to the comments of the Staff (the “Staff”) of the Division of Corporation
Finance of the Securities and Exchange Commission (the “Commission”) relating to the Company’s Registration Statement
on Form F-4 (the “Registration Statement”). An electronic version of the amended Registration Statement (“Amendment
No. 1”) has been concurrently submitted with the Commission through its EDGAR system. The enclosed copy of Amendment No. 1 to
the Registration Statement has been marked to reflect changes made to the Registration Statement.

Set forth below are the responses of the Company
to the comments of the Staff’s letter to the Company, dated July 21, 2021, relating to the Registration Statement. For convenience
of reference, the text of the comments in the Staff’s letter has been reproduced in bold and italics herein. The Company has also
provided its response immediately after each numbered comment. We have included page numbers to refer to the location in Amendment No.
1 where the amended language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the
meanings assigned to such terms in Amendment No. 1 to the Registration Statement.

Questions and Answers about the Proposals, page 10

 1. Please add a Q&A that discloses all possible sources and extent of dilution that shareholders who elect not to redeem their
shares may experience in connection with the business combination. Provide disclosure of the impact of each significant source of dilution,
including the amount of equity held by founders, convertible securities, including warrants retained by redeeming shareholders, at different
redemption levels.

Response: The Company has added
a question and answer on page 21 to disclose fully-diluted stock ownership information based on different levels of redemption. Since
all ITAC warrants remain outstanding, regardless of whether the holder redeemed the common stock, there is no change in the number shares
issued upon exercise of ITAC warrants at the various redemption levels.

July 30, 2021

Page Two

What will be the relative equity stakes of ITAC's public stockholders...,
page 13

 2. You disclose the equity stake of stockholder groups assuming no redemption by ITAC public stockholders. Please revise to also
disclose the equity stake of these groups assuming maximum redemption by public stockholders.

Response: The Company acknowledges
the Staff’s comment and has revised the Registration Statement to reflect maximum redemption. Please see page 13 of Amendment
No. 1.

I am an ITAC warrant holder. Why am I receiving this proxy statement/prospectus?,
page 17

 3. Please clarify whether public shareholders
                                            that redeem their shares will retain any warrants. If so, quantify the value of warrants,
                                            based on recent trading prices, that may be retained by redeeming stockholders assuming maximum
                                            redemptions and identify any material resulting risks.

Response: The Company has added
a risk factor “Although holders of ITAC Common Stock who own ITAC Warrants will receive Arbe Warrants if they redeem their ITAC
Common Stock, there are risks attendant to the ownership of the Arbe Warrants”. Please see page 65 of Amendment No. 1.

Interests of ITAC’s Officers and Directors in the Merger,
page 26

 4. Please disclose if the sponsor and the
                                            company’s officers and directors have any fiduciary or contractual obligations to other
                                            entities as well as any interest in, or affiliation with, the target company. If so, clarify
                                            how the board considered such conflicts in negotiating and recommending the business combination.
                                            Also, we note ITAC's charter waived the corporate opportunities doctrine. Please address
                                            this potential conflict of interest and whether it impacted ITAC's search for an acquisition
                                            target.

Response: The Sponsor and ITAC’s
officers and directors do not have any fiduciary or contractual obligations to other entities, except that, as disclosed in the Registration
Statement under the caption “Interests of ITAC’s Officers and Directors in the Merger,” ITAC’s officers, E. Scott
Crist, who is Chief Executive Officer, chairman and a director, and R. Greg Smith, the Chief Financial Officer, hold the same positions
with, and the other three directors are nominees for director of, Industrial Tech Acquisitions II, Inc., which has filed a Registration
Statement for an initial public offering which, as of the date of this letter, has not been declared effective by the Commission. No officer
or director of ITAC has any fiduciary or contractual obligation to or any interest in the Company. Article X of ITAC’s current certificate
of incorporation provides that, to the extent permitted by law, the doctrine of corporate opportunity does not apply to the ITAC or any
of its officers and directors. However, all of the activities relating to the search for an acquisition candidate were conducted on behalf
of ITAC with a view to entering into a business combination agreement with a company that the directors thought would bring value to its
stockholders. Please see page 99 of Amendment No. 1.

July 30, 2021

Page Three

Agreements entered into in connection with the Business Combination
Agreement

PIPE Subscription Agreements, page 28

 5. Please highlight any material differences in the terms and price of securities issued at the time of the IPO as compared to
the PIPE investment. Disclose if the PIPE investors include ITAC's sponsor, directors, officers or their affiliates.

Response: The Company has added
language describing the relationship between the price paid by the PIPE Investors and both the IPO price and the per share value of the
Arbe Ordinary Shares in the Merger under “PIPE Subscription Agreements” on page 121 and under “PIPE” on page 192.
The disclosure also states that entities affiliated with the Sponsor and the Company’s chief executive officers are investors in
the PIPE financing.

Historical Comparative and Pro Forma Combined Per Share Data
of ITAC and Arbe, page 36

 6. We note you include a reference to a footnote (3) in your table; however, there does not appear to be a footnote (3) disclosed.
Please revise or advise.

Response: The Company acknowledges
the Staff’s comment and has deleted the footnote reference from the Registration Statement. Please see page 38 of Amendment No.
1.

Risk Factors

Arbe relies on third-party suppliers..., page 48

 7. You disclose on page F-8 that you depend on a certain supplier for the development and production of your products. Please identify
your supplier and disclose the material terms of your agreements with it. Also, file any contracts with the supplier as exhibits or tell
us why this is not required.2

Response: The supplier referred
to in the financial statements is Global Foundries, which is a major semiconductor manufacturer. Consistent with industry practice, the
Company does not have an agreement with Global Foundries for the manufacturing of development stage wafers and purchases silicon wafers
pursuant to purchase orders. The Company has expanded the risk factor “Arbe relies on third-party suppliers and, because some of
the key components in its products come from limited or sole sources of supply, Arbe is susceptible to supply shortages, long lead times
for components and supply changes, any of which could disrupt its supply chain and could delay deliveries of its products to customers.”
to include language to refer to this supplier and to reflect the specific risks attendant to reliance on a sole supplier for semiconductors.
Disclosure of Global Foundries is included in the section “Business of Arbe – Manufacturing.” Please see pages 50
and 169 of Amendment No. 1.

July 30, 2021

Page Four

Risks Relating to the Business Combination, page 61

 8. Please add a risk factor that discusses the material risks to unaffiliated investors presented by taking the company public
through a merger rather than an underwritten offering. These risks could include the absence of due diligence conducted by an underwriter
that would be subject to liability for any material misstatements or omissions in a registration statement.

Response: The Company acknowledges
the Staff’s comment and added a risk factor “By entering into a business combination with ITAC, which is a SPAC, investors
may not have the same benefits as an investor in an underwritten public offering.” Please see page Please see page 67 of Amendment
No. 1.

The Sponsor has a different economic interest in the completion
of the Merger than the Public Stockholders, page 73

 9. Please disclose if the sponsor and its affiliates can earn a positive rate of return on their investment, even if other SPAC
shareholders experience a negative rate of return in the post-business combination company.

Response: The Company acknowledges
the Staff’s comment and has added a risk factor “The sponsor and its affiliates can earn a positive rate of return on their
investment, even if other SPAC shareholders experience a negative rate of return in the post-business combination company.” Please
see page 65 of Amendment No. 1.

Certain Unaudited Prospective Financial Information of Arbe

Satisfaction of the 80% Test, page 96

 10. Please describe how the ITAC board arrived at its valuation for Arbe, including a description of any financial models or analyses
the board considered.

Response: The Company has included
language under “The ITAC Board of Directors’ Reasons for the Merger” to include more specific disclosure relating to
ITAC’s evaluation of the Company. Please see page 96 of Amendment No. 1.

July 30, 2021

Page Five

U.S. Federal Income Tax Considerations of the Merger, page 121

 11. We note that the parties "intend" for the business combination to be a reorganization within the meaning of Section
368(a) of the Tax Code. However, the disclosure does not indicate whether the parties expect the business combination to be tax-free (with
respect to the receipt of stock) to U.S. holders. Revise to make clear whether the parties expect the business combination to be tax-free
to U.S. holders. If you are unable to conclude that the business combination is likely to be tax-free, revise your risk factor relating
to the material tax consequences of the business combination (page 63) to focus on the uncertainty and the consequences of the business
combination being taxable to U.S. holders. If you are able to conclude that the business combination is likely to be tax-free to U.S.
holders, include a tax opinion supporting such a conclusion. For further guidance see Staff Legal Bulletin No. 19 (October 14, 2011) and
Item 601(b)(8) of Regulation S-K.

Response: ITAC and the Company,
after consultation with their respective tax counsel, do not believe they can conclude that the business combination is likely to be tax-free
to US Holders of ITAC Common Stock. They have, however, in response to the comments from the Commission, made revisions to the US tax
disclosure to reflect the uncertainty and the consequences if the business combination is determined not to qualify as a tax-free reorganization.
Please see page 126 of Amendment No. 1.

Unaudited Pro Forma Condensed Combined Financial Information,
page 186

 12. We note the number of pro forma shares outstanding under each scenario as shown in the table on page 188 does not agree to the
number of pro forma shares disclosed in the footnotes to your pro forma balance sheets on pages 190 and 192, respectively. Please revise
or advise.

Response: The total number of shares
being issued to existing Arbe shareholders in the table on page 193 reflects the number of Arbe Ordinary Shares that will be outstanding
at the Closing, after giving effect (i) to the Recapitalization and (ii) the issuance of shares subsequent to December 31, 2020 that are
not related to the Merger. As described in the F-4, pursuant to the Recapitalization, (s) all outstanding warrants will be exercised (other
than those warrant are designed in the F-4 as Continuing Arbe Warrants) and upon such exercise, ordinary and preferred shares will be
issued, (ii) all preferred shares will be converted into ordinary shares in accordance with the terms of the preferred shares, and (iii)
the ordinary shares will be recapitalized, based upon the agreed upon valuation and a $10.00 price per Arbe Ordinary Share. Using this
computation, the existing Arbe shareholders will hold 48,275,832 ordinary shares, and the total ordinary shares outstanding at Closing
is 67,956,568 assuming no redemption and 60,332,968 assuming maximum redemption.

The pro forma financial statements reflect
the capitalization as of December 31, 2020 assuming no redemption and assuming maximum redemption. The number of ordinary shares at December
31, 2020, on a pro forma basis, are 64,643,935 assuming no redemption and 57,020,335 assuming maximum reduction. In each case, the difference
between the numbers on page 193 and the numbers on pages 195 and 197 is 3,312,633 ordinary shares. In preparing the pro forma financial
statements, the Company started with the shares outstanding at December 31, 2020 and adjusted that number to reflect shares that are issued
in connection with the Merger, such as the PIPE investment. The pro forma financial statements do not (and should not) reflect stock issuances
subsequent to December 31, 2020 that are not related to the business combination but were issued subsequent to the balance sheet date.

July 30, 2021

Page Six

For the information of the staff, the
3,312,633 shares reflect, primarily, funds raised in January 2021 as the last installment pursuant to an investment agreement that was
entered into in the first quarter of 2021 and is described in Note 15(a) of Arbe’s financial statements representing shares issuable
prior to the closing, and, to a lesser extent, warrants that were issued in 2021 and the exercise of employee stock options in 2021.

Since the pro forma balance sheets
on pages 194 and 196 relate to the December 31, 2020 balance sheet, the pro forma adjustment relate to adjustments to that balance
sheet and the number of Arbe shares outstanding on such date. The table on page 193 is a snapshot of the outstanding ordinary
shares at the Closing and reflects the 3,312,633 ordinary shares issued subsequent to December 31, 2020 in transactions not related
to the business combination. Thus, the numbers are different because they present different information.

 13. We note you do not reflect any par value for the pro forma common stock to be outstanding subsequent to the transactions. Additionally,
we note the entire amount of $100M from the issuance of shares to the PIPE investors is reflected within additional paid-in capital per
pro forma adjustment (J). Please tell us why there is no par value reflected in the pro forma common stock line item for the shares to
be issued and outstanding subsequent to the transact

United States securities and exchange commission logo
July 21, 2021
Jacob (Kobi) Marinka
Chief Executive Officer and Director
Arbe Robotics Ltd.
HaHashmonaim St. 107
Tel Aviv-Yafo
Israel
Re:Arbe Robotics Ltd.
Registration Statement on Form F-4
Filed June 21, 2021
File No. 333-257250
Dear Mr. Marinka:
            We have reviewed your 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form F-4 filed June 21, 2021
Questions and Answers about the Proposals, page 10
1.Please add a Q&A that discloses all possible sources and extent of dilution that
shareholders who elect not to redeem their shares may experience in connection with the
business combination. Provide disclosure of the impact of each significant source of
dilution, including the amount of equity held by founders, convertible securities, including
warrants retained by redeeming shareholders, at different redemption levels.

 FirstName LastNameJacob (Kobi) Marinka
 Comapany NameArbe Robotics Ltd.
 July 21, 2021 Page 2
 FirstName LastName
Jacob (Kobi) Marinka
Arbe Robotics Ltd.
July 21, 2021
Page 2
What will be the relative equity stakes of ITAC's public stockholders..., page 13
2.You disclose the equity stake of stockholder groups assuming no redemption by ITAC
public stockholders.  Please revise to also disclose the equity stake of these
groups assuming maximum redemption by public stockholders.
I am an ITAC warrant holder. Why am I receiving this proxy statement/prospectus?, page 17
3.Please clarify whether public shareholders that redeem their shares will retain any
warrants. If so, quantify the value of warrants, based on recent trading prices, that may be
retained by redeeming stockholders assuming maximum redemptions and identify any
material resulting risks.
Interests of ITAC’s Officers and Directors in the Merger, page 26
4.Please disclose if the sponsor and the company’s officers and directors have any fiduciary
or contractual obligations to other entities as well as any interest in, or affiliation with, the
target company.  If so, clarify how the board considered such conflicts in negotiating and
recommending the business combination.  Also, we note ITAC's charter waived the
corporate opportunities doctrine. Please address this potential conflict of interest and
whether it impacted ITAC's search for an acquisition target.
Agreements entered into in connection with the Business Combination Agreement
PIPE Subscription Agreements, page 28
5.Please highlight any material differences in the terms and price of securities issued at the
time of the IPO as compared to the PIPE investment. Disclose if the PIPE investors
include ITAC's sponsor, directors, officers or their affiliates.
Historical Comparative and Pro Forma Combined Per Share Data of ITAC and Arbe, page 36
6.We note you include a reference to a footnote (3) in your table; however, there does not
appear to be a footnote (3) disclosed.  Please revise or advise.
Risk Factors
Arbe relies on third-party suppliers..., page 48
7.You disclose on page F-8 that you depend on a certain supplier for the development and
production of your products. Please identify your supplier and disclose the material terms
of your agreements with it.  Also, file any contracts with the supplier as exhibits or tell us
why this is not required.
Risks Relating to the Business Combination, page 61
8.Please add a risk factor that discusses the material risks to unaffiliated investors
presented by taking the company public through a merger rather than an underwritten
offering. These risks could include the absence of due diligence conducted by an

 FirstName LastNameJacob (Kobi) Marinka
 Comapany NameArbe Robotics Ltd.
 July 21, 2021 Page 3
 FirstName LastNameJacob (Kobi) Marinka
Arbe Robotics Ltd.
July 21, 2021
Page 3
underwriter that would be subject to liability for any material misstatements or omissions
in a registration statement.
The Sponsor has a different economic interest in the completion of the Merger than the Public
Stockholders, page 73
9.Please disclose if the sponsor and its affiliates can earn a positive rate of return on
their investment, even if other SPAC shareholders experience a negative rate of return in
the post-business combination company.
Certain Unaudited Prospective Financial Information of Arbe
Satisfaction of the 80% Test, page 96
10.Please describe how the ITAC board arrived at its valuation for Arbe, including a
description of any financial models or analyses the board considered.
U.S. Federal Income Tax Considerations of the Merger, page 121
11.We note that the parties "intend" for the business combination to be a reorganization
within the meaning of Section 368(a) of the Tax Code. However, the disclosure does not
indicate whether the parties expect the business combination to be tax-free (with respect to
the receipt of stock) to U.S. holders. Revise to make clear whether the parties expect the
business combination to be tax-free to U.S. holders. If you are unable to conclude that the
business combination is likely to be tax-free, revise your risk factor relating to the material
tax consequences of the business combination (page 63) to focus on the uncertainty and
the consequences of the business combination being taxable to U.S. holders. If you are
able to conclude that the business combination is likely to be tax-free to U.S. holders,
include a tax opinion supporting such a conclusion. For further guidance see Staff Legal
Bulletin No. 19 (October 14, 2011) and Item 601(b)(8) of Regulation S-K.
Unaudited Pro Forma Condensed Combined Financial Information, page 186
12.We note the number of pro forma shares outstanding under each scenario as shown in the
table on page 188 does not agree to the number of pro forma shares disclosed in the
footnotes to your pro forma balance sheets on pages 190 and 192, respectively.  Please
revise or advise.
13.We note you do not reflect any par value for the pro forma common stock to be
outstanding subsequent to the transactions.  Additionally, we note the entire amount of
$100M from the issuance of shares to the PIPE investors is reflected within additional
paid-in capital per pro forma adjustment (J).  Please tell us why there is no par value
reflected in the pro forma common stock line item for the shares to be issued and
outstanding subsequent to the transactions, or revise accordingly.
14.We note that Pro Forma Loss per Share on page 197 has been adjusted to reflect the
exercise of 19,804 warrants into Arbe Ordinary Shares.  However, there do not appear to

 FirstName LastNameJacob (Kobi) Marinka
 Comapany NameArbe Robotics Ltd.
 July 21, 2021 Page 4
 FirstName LastNameJacob (Kobi) Marinka
Arbe Robotics Ltd.
July 21, 2021
Page 4
be any adjustments to the pro forma financial statements for this transaction.  Please
advise.
3. Adjustments to Unaudited Pro Forma Condensed Combined Financial Information, page 195
15.We note your references to including adjustments that are directly attributable to the
Transactions, factually supportable and expected to have a continuing impact.  Please
revise your disclosures to comply with the updated guidance in Article 11-02 of
Regulation S-X.
Beneficial Ownership of Arbe Securities, page 209
16.Please disclose the portion of each class of Arbe securities held in the United States and
the number of record holders in the United States. Refer to Item 18 of Form F-4 and Item
7.A.2 of Form 20-F.
Notes to the Consolidated Financial Statements for Arbe Robotics LTD.
Note 3: Revenue, page F-15
17.Please revise to disclose the amount of revenue recognized in 2020 that was included in
deferred revenue as of December 31, 2019.  Refer to ASC 606-10-50-8(b).
18.Please revise to separately disclose revenue from any individual foreign country, if
material, or to state that no one country generated a significant amount of revenue.  Refer
to ASC 280-10-50-41(a).
Note 7: Convertible Loan, page F-17
19.We note that the December 2020 convertible loan will convert into equity upon the
occurrence of certain events, and that per pro forma adjustment (H) it will convert as part
of the merger transaction.  Please revise to disclose the nature of these "certain events,"
including the fact that the loan will convert upon completion of this transaction.
Note 15. Subsequent Events, page F-26
20.Revise to disclose the date that the financial statements were issued.  Refer to ASC 855-
10-50-1(a).
Item 21. Exhibits and Financial Statement Schedules, page II-1
21.Please file any material lease agreements and the employment agreements with your
executive officers as exhibits to your registration statement. Refer to Item 21 of Form F-4
and Item 601(b)(10) of Regulation S-K.
            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.

 FirstName LastNameJacob (Kobi) Marinka
 Comapany NameArbe Robotics Ltd.
 July 21, 2021 Page 5
 FirstName LastName
Jacob (Kobi) Marinka
Arbe Robotics Ltd.
July 21, 2021
Page 5
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Brittany Ebbertt, Senior Staff Accountant, at (202) 551-3572 or
Christine Dietz Senior Staff Accountant at (202) 551-3408 if you have questions regarding
comments on the financial statements and related matters.  Please contact Matthew Crispino,
Staff Attorney, at (202) 551-3456 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Asher S. Levitsky