SecProbe.io

CORRESP
 1
 filename1.htm

 ETORO GROUP LTD.
30 Sheshet Hayamim St.
Bnei Brak, Israel 5120261

 May 9, 2025

 VIA EMAIL & EDGAR

 Securities and Exchange Commission
Division of Corporation Finance

 100 F Street, N.E.
Washington, DC 20549-3561

 Re: eToro Group Ltd. (the "Company") Registration
 Statement on Form F-1 (Registration No. 333-286050)

 Ladies and
Gentlemen:

 Pursuant to Rule 461(a) of the General Rules and Regulations under the Securities Act of 1933, as amended, we respectfully request that
the effective date of the Company's Registration Statement on Form F-1 (File No. 333-286050) be accelerated by the Securities and Exchange
Commission to 4:00 p.m. Eastern Time on May 13, 2025, or as soon as practicable thereafter.

 We request that we be notified
of such effectiveness by a telephone call to David Goldschmidt of Skadden, Arps, Slate, Meagher & Flom LLP at (212) 735-3574 and that
such effectiveness also be confirmed in writing.

 Very truly yours,

 eToro Group Ltd.

 By:
 /s/ Jonathan Alexander Assia

 Name:
 Jonathan Alexander Assia

 Title:
 Chief Executive Officer

 Enclosure

 Cc
 Jonathan Alexander Assia, Chief Executive Officer

 Debbie Kahal, Chief Legal Officer

 eToro Group Ltd.

 David J. Goldschmidt, Esq.
 Skadden, Arps, Slate, Meagher & Flom LLP

 Marc D Jaffe, Esq.

 Joshua G. Kiernan, Esq.

 Gilad Zohari, Esq.

 Michael J. Rosenberg, Esq.

 Latham & Watkins LLP

CORRESP
 1
 filename1.htm

 Goldman Sachs & Co. LLC

 200 West Street

 New York, New York 10282

 Jefferies LLC

 520 Madison Avenue

 New York, New York 10022

 UBS Securities LLC

 1285 Avenue of the Americas

 New York, New York 10019

 Citigroup Global Markets Inc.

 388 Greenwich Street

 New York, New York 10013

 May 9, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Crypto Assets

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: David Irving

 Mark Brunhofer

 Irene Paik

 Sandra Hunter Berkheimer

 Re: eToro Group Ltd.

 Registration Statement on Form F-1

 Filed May 5, 2025

 File No. 333-286050

 Acceleration Request

 Requested Date: May 13, 2025

 Requested Time: 4:00 P.M. Eastern Time

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act
of 1933, as amended (the "Securities Act"), we, as the representatives of the several underwriters (the "Representatives"),
hereby join in the request of eToro Group Ltd., a company organized under the laws of the British Virgin Islands (the "Company"),
that the effective date of the above-referenced Registration Statement on Form F-1 be accelerated so that it will be declared effective
at 4:00 p.m. Eastern Time, on May 13, 2025, or as soon thereafter as practicable, or at such other time thereafter as the Company or its
outside counsel, Skadden, Arps, Slate, Meagher & Flom LLP, may request by telephone to the staff of the Securities and Exchange Commission.

 Pursuant to Rule 460 under the Securities Act,
we, as the Representatives, wish to advise you that we will take reasonable steps to secure adequate distribution of the preliminary prospectus
to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement.

 We, the undersigned Representatives, hereby
represent that we are in compliance and will comply, and have been informed by the other participating underwriters that they are in compliance
and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the offering
pursuant to the above-referenced Registration Statement and Preliminary Prospectus.

 [ Signature Page Follows ]

 Very truly yours,

 Goldman Sachs & Co. LLC

 Jefferies LLC

 UBS Securities LLC

 Citigroup Global Markets Inc.

 As Representatives of the several Underwriters

 GOLDMAN SACHS & CO. LLC

 By:
 /s/ Danielle Freeman

 Name:
 Danielle Freeman

 Title:
 Managing Director

 JEFFERIES LLC

 By:
 /s/ Alexander Yavorksy

 Name:
 Alexander Yavorksy

 Title:
 Joint Global Head of Financial Institutions Group

 UBS SECURITIES LLC

 By:
 /s/ Adam Kerbis

 Name:
 Adam Kerbis

 Title:
 Executive Director

 By:
 /s/ Alex Cahail

 Name:
 Alex Cahail

 Title:
 Director

 CITIGROUP GLOBAL MARKETS INC.

 By:
 /s/ Patrick Leonard

 Name:
 Patrick Leonard

 Title:
 Managing Director

CORRESP
 1
 filename1.htm

 Skadden,
Arps, Slate, Meagher & Flom llp One Manhattan West New York, NY 10001

 TEL: (212) 735-3000 FAX: (212) 735-2000

 www.skadden.com

 April
1, 2025
 FIRM/AFFILIATE
OFFICES
-----------
BOSTON
CHICAGO
HOUSTON
LOS ANGELES
PALO ALTO
WASHINGTON,
D.C. WILMINGTON
-----------
ABU DHABI
BEIJING
BRUSSELS
FRANKFURT
HONG KONG
LONDON
MUNICH
PARIS
SÃO PAULO
SEOUL
SINGAPORE
TOKYO
TORONTO

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Crypto Assets

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn:
 David Irving

 Mark Brunhofer

 Irene Paik

 Sandra Hunter Berkheimer

 RE:
 eToro Group Ltd.

 Registration Statement on Form F-1 (File No. 333-286050)

 Submitted March 24, 2025

 CIK No. 0001493318

 Ladies and Gentlemen:

 On behalf of our client, eToro
Group Ltd. (the " Company "), we hereby provide information in response to oral requests from the staff (the " Staff ")
of the U.S. Securities and Exchange Commission (the " Commission ") with respect to the above-referenced Registration
Statement on Form F-1 (File No. 333-286050) submitted to the Commission on March 24, 2025 (the " Registration Statement ").

 Draft Beneficial Ownership Table

 Shares Beneficially Owned Prior to this Offering
 % of Voting Power Prior
 Class A Common Shares
 Shares Beneficially Owned After this Offering
 % of Voting Power

 Class A
 Class B
 to this
 Being
 Class A
 Class B
 After this

 Name of Beneficial Owner
 Number
 %
 Number
 %
 Offering
 Offered
 Number
 %
 Number
 %
 Offering

 5% or Greater Shareholders and Selling Shareholders

 Spark Capital II, L.P. (1)

 BRM Group Ltd. (2)

 Andalusian SPV III, LP (3)

 SBT Venture Fund I (4)

 CM SPC on behalf of CM Equities SP (5)

 Executive Officers and Directors

 Yoni Assia (6)

 Meron Shani (7)

 Hedva Ber (8)

 Tuval Chomut (9)

 Ronen Assia (10)

 Santo Politi (1)

 Avner Stepak (11)

 Eddy Shalev (12)

 All Directors and Executive Officers as a group (8 persons) (13)

 Other Selling Shareholders

 David Ring (14)

 [3.35] %

 Commerzventures Beteiligungs GmbH & Co. KG (15)

 [2.28] %

 Cubit Investments Ltd. (16)

 [1.62] %

 Capybara Ltd. (17)

 [1.41] %

 David Assia (18)

 [1.30] %

 Fintech Business Innovation LPS (19)

 [1.25] %

 Hanina Brandes (20)

 [1.15] %

 Entities affiliated with iAngels (21)

 *

 Non-employee selling shareholders that beneficially own
 less than [140,000] 1 shares of Class A common shares (22)

 [11.01] %

 Employee selling shareholders that beneficially own less than [140,000] shares of Class A common shares (23)

 [8.35] %

 * Amounts represent less than 1% of issued and outstanding
common shares.

 1 NTD : To account for share split.

 2

 (1) Represents our Class A common shares and Class B common
shares held by Spark Capital II, L.P., Spark Capital Founders' Fund II, L.P., Spark Capital Growth Fund II, L.P.,
Spark Capital Growth Founders' Fund II, L.P., Spark Capital Growth Fund III, L.P. and Spark Capital Growth Founders'
Fund III, L.P. (each, a "Spark Entity"). Spark Capital II, L.P. and Spark Capital Founders' Fund II, L.P. are
controlled by their general partner, Spark Management Partners II, LLC, which is governed by a single managing member, including
Santo Politi, who is one of our directors. Spark Capital Growth Fund II, L.P. and Spark Capital Growth Founders' Fund II, L.P.
are controlled by their general partner, Spark Growth Management Partners II, LLC, which is governed by its two managing members, including
one of our directors, Santo Politi. Spark Capital Growth Fund III, L.P. and Spark Capital Growth Founders' Fund III, L.P.
are controlled by their general partner, Spark Growth Management Partners III, LLC, which is governed by its three managing members,
including one of our directors, Santo Politi. The managing members of each general partner make investment and voting decisions based
on a majority vote. To the extent Mr. Santo Politi may be deemed to have beneficial ownership over the shares beneficially owned
by any Spark Capital Entity, he expressly disclaims such beneficial ownership. The business address of each of the foregoing persons
is 200 Claredone Street, Floor 59, Boston, Massachusetts 02116.

 (2) Represents our Class A common shares and Class B common
shares held by BRM Group Ltd., and its affiliated entities Eli Barkat Ltd. and Yuval Rakavi Ltd. Investment and voting power of the shares
is exercised by the executives of BRM Group Ltd., who are Arie Nachmias, Chief Financial Officer, and Eli Barkat, Active Chairman. The
business address of each of the foregoing persons is 10 Nissim Aloni St., Tel Aviv, Israel. Eli Barkat Ltd. and Yuval Rakavi Ltd., who
are the indirect owners of BRM Group Ltd., hold 370,780 of our Class A common shares.

 (3) Represents our Class A common shares and Class B common
shares held by Andalusian SPV III, LP and its affiliated and its affiliated entity Turkoman Partners, LP, which is controlled by
its general partner, Andalusian SPV II GP, LP. Turkoman Partners, LP is controlled by two general partners, Jeffrey Kaplan
and Nicholas Savasta The business address of each of the foregoing persons is 51 John F. Kennedy Pkwy Short Hills, NJ 07078.

 (4) Represents our Class A common shares and Class B common
shares held by SBT Venture Fund I, L.P. ("SBT"). SBT is governed by its general partner, FRV I, GP ("FRV I"),
which is governed by a board of directors consisting of three members, none of whom possesses control. The majority limited partner of
SBT is Digital Technology LLC, a wholly-owned subsidiary of JSC Sberbank of Russia, a Russian financial institution, which is subject
to U.S., U.K., E.U. and BVI sanctions (the "Sanctions"). As a result of the Sanctions and as provided under the current memorandum
and articles and the A&R memorandum and articles, SBT is restricted from exercising its voting rights in us, transferring its shares
and from receiving new shares and distributions or dividends (the "Sanctions Restrictions") as long as it is subject to the
Sanctions Restrictions. Accordingly, SBT did not receive, and will not receive, as long as it is subject to the Sanctions Restrictions,
Class B common shares pursuant to the Class B Distribution. In addition, in connection with the conversion contemplated under the terms
of that certain Advanced Investment Agreement, entered into in February 2021, SBT would have been entitled to the issuance of 60,303
Preferred F shares, which under the Recapitalization would have converted into Class A common shares that would be entitled to a distribution
of Class B common shares pursuant to the Class B Distribution. In light of the Sanctions Restrictions, such Preferred F shares and the
resulting Class A common shares and Class B common shares that would have been held by SBT, were not and will not be, as long as SBT
is subject to the Sanctions Restrictions, issued. The registered office address of SBT is c/o FFP (Corporate Services) Limited, 2 nd
Floor Harbour Centre, 159 Mary Street, George Town, Grand Cayman, KY1-9906, Cayman Islands and of FRV I is c/o AIF Corporate Services
Ltd, Piccadilly Centre, 28 Elgin Avenue, Suite 201, PO Box 2570, George Town, KY1-1103, Cayman Islands.

 (5) Represents our Class A common shares and Class B common
shares held by CM SPC on behalf of CM Equities SP. Investment and voting power of the shares is exercised by the board of directors
of CM SPC, who are Guo Yifan, Xie Fang and Zhao Zhaoran. The business address of each of the foregoing persons is Suites 2803-04,
28/F, South Island Place, 8 Wong Chuk Hang Road, Hong Kong.

 (6) Consists of (i) of
our Class A common shares held by Yoni Assia, (ii) of our
Class B common shares held by Yoni Assia, (iii) of our Class A
common shares and of our Class B common shares subject to options
held by Yoni Assia that are exercisable within 60 days of March 31, 2025 and (iv) of
our Class A common shares and of our Class B common shares
subject to options that are held by Capital V5 PTE. LTD., a company wholly-owned by Yoni Assia, that are exercisable within 60 days
of , 2025. Mr. Yoni Assia's holding excludes (x)
of our Class A common shares and of our Class B common shares
held by iAngels Technologies L.P. or iAngels Crowd Ltd. (together, "iAngels"), whose Chief Executive Officer, director and
owner is Yoni's spouse and (y) of our Class A common shares
and of our Class B common shares held by Raid 5 Ltd. on behalf
of Pentagon V5 Trust for the benefit of Yoni Assia's minor children, which investment power and voting power is exercised by a
third party trustee. To the extent Mr. Yoni Assia may be deemed to have beneficial ownership over the shares beneficially owned by iAngels
and Raid 5 Ltd. on behalf of Pentagon V5 Trust, he expressly disclaims such beneficial ownership.

 (7) Consists of of
our Class A common shares and of our Class B common shares
subject to options held by Meron Shani that are exercisable within 60 days of March 31, 2025.

 (8) Consists of of
our Class A common shares and of our Class B common shares
subject to options held by Hedva Ber that are exercisable within 60 days of March 31, 2025.

 (9) Consists of of
our Class A common shares and of our Class B common shares
subject to options held by Tuval Chomut that are exercisable within 60 days of March 31, 2025.

 3

 (10) Consists of (i) of
our Class A common shares held by Ronen Assia, (ii) of our
Class B common shares held by Ronen Assia and (iii) of our Class A
common shares and of our Class B common shares subject to options
held by Ronen Assia that are exercisable within 60 days of March 31, 2025. Ronen Assia's holding excludes
of our Class A common shares and of our Class B common shares
held by held by Capybara Ltd. on behalf of The Giving Tree Trust, for the benefit of the minor children of Ronen Assia, which investment
and voting power of the shares is exercised by an unrelated third party. To the extent Mr. Ronen Assia may be deemed to have beneficial
ownership over the shares beneficially owned by Capybara Ltd., he express disclaims such beneficial ownership.

 (11) Consists of (i) of
our Class A common shares and of our Class B common shares
subject to options held by Avner Stepak that are exercisable within 60 days of March 31, 2025, (ii) of
our Class A common shares held by Shira 10, a company that is controlled by Avner Stepak and (iii) of
our Class B common shares held by Shira 10, a company that is controlled by Avner Stepak.

 (12) Consists of (i) of
our Class A common shares and of our Class B common shares
subject to options held by Eddy Shalev that are exercisable within 60 days of March 31, 2025, (ii) of
our Class A common shares held by Levera S.A., a company that is wholly owned by Eddy Shalev and (iii) of
our Class B common shares held by Levera S.A., a company that is wholly owned by Eddy Shalev.

 (13) Consists of (i) of
our Class A common shares, (ii) of our Class B common
shares and (iii) of our Class A common shares and of
our Class B common shares subject to options that are exercisable within 60 days of March 31, 2025.

 (14) Consists of of
our Class A common shares and of our Class B common shares.

 (15) Consists of of
our Class A common shares and of our Class B common shares.

 (16) Consists of of
our Class A common shares and of our Class B common shares.

 (17) Consists of of
our Class A common shares and of our Class B common shares. Capybara
Ltd. holds such shares on behalf of The Giving Tree Trust, for the benefit of the minor children of Ronen Assia, which investment and
voting power of the shares is exercised by an unrelated third party. To the extent Mr. Ronen Assia may be deemed to have beneficial ownership
over the shares beneficially owned by Capybara Ltd., he express disclaims such beneficial ownership.

 (18) Consists of of
our Class A common shares and of our Class B common shares. David
Assia is the father of Yoni Assia.

 (19) Consists of of
our Class A common shares and of our Class B common shares.

 (20) Consists of of
our Class A common shares and of our Class B common shares.

 (21) Consists of of
our Class A common shares and of our Class B common shares held
by iAngels Technologies LP and iAngels Crowd Ltd. (in trust). Yoni Assia's wife is the Chief Executive Officer, director and owner
of iAngels. To the extent Mr. Yoni Assia may be deemed to have beneficial ownership over the shares beneficially owned by iAngels, he
expressly disclaims such beneficial ownership.

 (22) Consists of of
our Class A common shares and of our Class B common shares held
by [43] investors who each individually beneficially own less than 1.0% of our outstanding share capital.

 (23) Consists of (i) of
our Class A common shares, (ii) of our Class B common shares and
(iii) of our Class A common shares and of our Class B common
shares subject to options that are exercisable within 60 days of March 31, 2025 held by [245] current and former employees and
other service providers who each individually beneficially own less than 1.0% of our outstanding share capital.

 4

 Please contact me at (212) 735-3574 or David.Goldschmidt@skadden.com
if the Staff has any questions or requires additional information.

 Sincerely,

 SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP

 /s/ David J. Goldschmidt

 David J. Goldschmidt, Esq.

 Partner

 Enclosure

 Cc
 Jonathan Alexander Assia, Chief Executive Officer

 Debbie Kahal, Chief Legal Officer

 eToro Group Ltd.

 Marc D Jaffe, Esq.

 Joshua G. Kiernan, Esq.

 Gilad Zohari, Esq.

 Michael J. Rosenberg, Esq.

 Latham & Watkins LLP

 5

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 10, 2025

Jonathan Alexander Assia
Chief Executive Officer
eToro Group Ltd.
30 Sheshet Hayamim St.,
Bnei Brak, Israel 5120261

 Re: eToro Group Ltd.
 Amendment No. 4 to Draft Registration Statement on Form F-1
 Submitted March 3, 2025
 CIK No. 0001493318
Dear Jonathan Alexander Assia:

 We have reviewed your amended draft registration statement and have the
following
comments.

 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 a comment applies 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 this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our January 10, 2025 letter.

Amendment No. 4 to Draft Registration Statement on Form F-1
Market, Industry and Other Data
Testimonials, page 3

1. Please ensure that the testimonials provided throughout the prospectus
are not so
 extensive that they obscure other prospectus disclosure. In addition,
please confirm
 that you have received consents to the inclusion of the quotes in the
prospectus from
 the relevant individuals. Please also disclose whether any of these
individuals were
 compensated for their testimonials.
 March 10, 2025
Page 2
Index to Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 2 - Significant Accounting Policies, page F-9

2. Please revise your next amendment to provide additional information
regarding your
 $65 million short-term investment, including the nature of the
investment, terms, and
 your accounting policy.
U. Financial Instruments
(4) Hedge accounting, page F-23

3. Please revise your policy to clarify how you account for the fair value
hedges related
 to your employee investment plan as disclosed in the last paragraph of
the footnote.
Note 17 - Taxes on Income
D. Pillar Two, page F-45

4. Please tell us, and revise your disclosure accordingly, why you do not
expect to be
 within the scope of Pillar Two at December 31, 2024 when you also
disclose that
 multinational enterprises with global revenues of at least 750
million in at least two
 of the previous four years are in the scope of Pillar Two. In this
regard, it appears that
 you have revenues in excess of 750 million in each of the last three
years.
F. Taxes on Income Included in Profit or Loss, page F-46

5. We note that $12,995,000 of your $53,238,000 income tax provision in
2024 is related
 to prior years. Please tell us why this provision, representing 24.4% of
your total
 provision and 5.3 percentage points of your total 21.7% effective tax
rate, is properly
 recorded in 2024. In your response specifically tell us why this
provision was not
 recorded in 2023 or an earlier period. Reference for us the
authoritative literature
 you relied upon to support your accounting.

 Please contact David Irving at 202-551-3321 or Mark Brunhofer at
202-551-3638 if
you have questions regarding comments on the financial statements and related
matters. Please contact Irene Paik at 202-551-6553 or Sandra Hunter Berkheimer
at 202-551-
3758 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
cc: David J. Goldschmidt
</TEXT>
</DOCUMENT>

January 10, 2025
Jonathan Alexander Assia
Chief Executive Officer
eToro Group Ltd.
30 Sheshet Hayamim St.,
Bnei Brak, Israel 5120261
Re:eToro Group Ltd.
Draft Registration Statement on Form F-1
Submitted December 6, 2024
CIK No. 0001493318
Dear Jonathan Alexander Assia:
            We have reviewed your draft registration statement and have the following comments.
            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 a comment applies 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 this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 Submitted December 6, 2024
General
1.We note your disclosure on page 31 that your crypto asset staking program is
currently unavailable to users in the United States. We further note your disclosure on
pages 98-99 that you plan to expand the range of services which you monetize,
including staking.  Please tell us how you plan to expand your staking services and if
you plan to expand them to users in the United States.
2.Your website indicates that you offer U.S. investors the opportunity to purchase
fractional shares. Please tell us if there have been any substantive or material changes
to your fractional share program since 2021.
Please define the terminology that you use on first use.  For example purposes only,
we note your use of the terms "users," "Funded Accounts," "CopyTrader," "Popular 3.

January 10, 2025
Page 2
Investors," and "Smart Portfolio."
4.Please supplementally provide us with copies of all written communications, as
defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so
on your behalf, present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not they retain copies of the communications.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Overview, page 90
5.We note your disclosure throughout that your platform serves users in 75 countries
across 20 languages.  Please identify the countries in which you serve users.
Key Performance Metrics
Adjusted Net Revenue and Components, page 92
6.We note that Adjusted Net Revenue reflects Total revenue and income less
Cost of revenue from cryptoassets and Margin interest expense. Please tell us whether
this key performance metric and the components of Net Trading Revenue
(Cryptoassets) and Net Interest Income are non-IFRS measures as defined by Item
10(e) of Regulation S-K and the basis for your conclusion.
Funded Accounts, page 93
7.Please clarify how recently a user must have executed a trade and have a positive
account balance in order to be considered a "funded account."
8.Please disclose here the portion of funded account growth resulting from acquisitions,
as opposed to organic growth. If material, please revise your risk factor "Our
historical growth rates may not be indicative of our future growth" accordingly. We
note, by way of example only, your 2022 acquisition of Gatsby.
Business, page 110
9.Please identify all of the services you provide to users, including the crypto asset
services that you provide for each crypto asset and disclose which services are
currently available to U.S. users. Please consider using a table or a chart to show the
crypto assets and crypto asset services. Please ensure that you clarify whether and to
what extent your CopyTrader and Smart Portfolio features are available to U.S users.
Please disclose how you utilize digital engagement practices in connection with your
platform, including behavioral prompts, differential marketing, game-like features,
and other design elements or features designed to engage with retail investors. Please
also address the following:
•Specifically describe the analytical and technological tools and methods you use
in connection with these practices and your use of technology to develop and
provide investment education tools.
•Clarify whether any practice is designed to or otherwise may encourage retail
investors to trade more often, invest in different products or change investment
strategies.
To the extent your use of any optimization functions may lead to potential •10.

January 10, 2025
Page 3
conflicts between your platform and investors, add related risk factor disclosure.
•We note your disclosure on pages 135-136 regarding data privacy and security.
Please revise to describe in greater detail your data collection practices or those of
your third-party service providers.
11.We note your disclosure that you are "actively exploring the utility of artificial
intelligence, or AI, deploying it across [y]our business to create more personalized
customer journeys and operational efficiencies." We also note your disclosure that
you use both proprietary and third-party technologies. Please revise to clarify whether
you intend to utilize open-source technology or license the use of such technology. To
the extent you intend to license existing or future technologies or plan to utilize
proprietary and/or open-source technology, please also add relevant risk disclosure to
address any related risks.
12.Please revise your disclosure to provide a materially complete discussion regarding
your artificial intelligence and machine learning capabilities, and how they operate. In
addition, clarify what datasets your artificial intelligence or algorithms use. Further,
please revise to provide a more complete description of how you intend to utilize
artificial intelligence in your products and describe your current phase of
development.
13.Please identify each of your "key markets." Please also revise throughout to clarify
how many key markets you have. For example, we note the reference to "all seven of
[y]our key markets" on page 117 and "five out of six of [y]our key markets" on page
124.
Our Users, page 119
14.We note from your website that you offer new user incentives and have a referral
program where you compensate both the existing referring user and new user. Please
tell us the amounts incurred in each period presented in your filing (including the
eventual update for annual 2024 financial information) for each of the following:
•new user incentives;
•referral programs; and
•any other award programs for users.
eToro Club, page 120
15.Please tell us the amounts incurred for each of the identified perks and exclusive
features provided to eToro Club members for each period presented in your filing
(including the eventual update for annual 2024 financial information).
Our Technology, page 122
16.Please disclose the basis for your statement on page 123 that your infrastructure is
"best-in-class."
State of Regulation, page 129
17.Under a separate subheading in this section, please provide a discussion of the
regulations applicable to the "social investing" aspects of your operations.

January 10, 2025
Page 4
Notes to Consolidated Financial Statements
Note 2. Significant Accounting Policies
r. Cryptoassets, page F-20
18.Please revise your next amendment to include a rollforward for each of your material
cryptoasset holdings in the periods presented.
            Please contact David Irving at 202-551-3321 or Mark Brunhofer at 202-551-3638 if
you have questions regarding comments on the financial statements and related
matters. Please contact John Dana Brown at 202-551-3859 or Sandra Hunter Berkheimer at
202-551-3758 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:David J Goldschmidt