December 17, 2018

Reuven Kitov
Chief Executive Officer
Tufin Software Technologies Ltd.
5 Shoham Street
Ramat-Gan 52521, Israel

       Re: Tufin Software Technologies Ltd.
           Draft Registration Statement on Form F-1
           Submitted November 20, 2018
           CIK No. 0001757399

Dear Mr. Kitov:

       We have reviewed your draft registration statement and have the
following comments. In
some of our comments, we may ask you to provide us with information so we may
better
understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-1

Our Growth Strategy, page 5

1.     You state that revenue generated from your Global 2000 customers
represented [currently
       blank] % of your sales during fiscal years 2015 to 2018. Please clarify
whether you intend
       to provide the percentage of cumulative revenues from your Global 2000
customers for
       the periods presented. If so, tell us the percentage of revenue
generated from such
       customers for each fiscal year individually. To the extent the
percentages differ from
       period to period, revise to disclose the percentage of revenue from your
Global 2000
       customers separately for each period presented or tell us why you
believe cumulative
       information is useful to investors.
 Reuven Kitov
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Tufin Software Technologies Ltd.
Comapany17, 2018
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Risk Factors
Risks Related to Our Business and Our Industry
If third-party applications and network products change..., page 16

2.       You state that you rely on technology that you license from third
parties. Please revise
         your business section to briefly describe these technologies and the
terms of the related
         license agreements to the extent material.
Because we derive substantially all of our revenues..., page 17

3.       You disclose that you generated substantially all of your fiscal year
2018 revenues from
         sales of licenses and maintenance for SecureTrack, SecureChange and
SecureApp and that
         your customers often initially deploy only SecureTrack. Please
disclose the percentage of
         revenue generated from sales of licenses and maintenance for
SecureTrack. If
         substantially all of your revenues are generated from sales of
SecureTrack, consider
         revising this risk factor to disclose your reliance on sales of
licenses and maintenance for
         this single product.
If we fail to maintain successful relationships with our channel partners...,
page 20

4.       You state that two of your channel partners accounted for 16% and 13%
of your revenues
         as of December 31, 2017. Please revise your business section to
describe the material
         terms of your agreements with these channel partners.
Prolonged economic uncertainties or downturns, page 25

5.       It appears you intend to disclose the percentage of your fiscal 2018
revenues generated
         from customers in the financial services and telecommunications
industries. For
         comparative purposes, please also provide the percentage of your
fiscal 2017 revenues
         generated from customers in these industries.
Risks Related to Our Ordinary Shares and the Offering
As a foreign private issuer..., page 30

6.       You disclose that a majority of your executive officers are U.S.
citizens or residents. You
         also note that you will lose your foreign private issuer status if a
majority of your directors
         or executive officers are U.S. citizens or residents and you fail to
meet certain other
         requirements. Please revise to briefly describe these other
requirements and to provide
         context concerning your ability to continue to meet these requirements
after the
         completion of this offering.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Factors Affecting Our Performance, page 51

7.       Please revise to clarify whether the cohort chart on page 52 includes
a customer's
 Reuven Kitov
FirstName LastNameReuven Kitov
Tufin Software Technologies Ltd.
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FirstName LastName
         maintenance renewal in subsequent years or whether the chart only
reflects the initial and
         follow-on sales of perpetual and term licenses. Also, considering your
focus on customer
         retention, please tell us if you consider customer churn to be a key
factor affecting your
         performance, and if so, disclose this metric for each reported period.
Refer to Item 5 of
         Form 20-F.
8.       You provide the number of new customers acquired during each of the
periods presented.
         Considering customer retention is a key factor impacting your
performance, tell us and
         consider disclosing the number of customers at each period end. Also,
tell us whether you
         separately monitor the number of large enterprise and non-enterprise
customers, and if so,
         disclose the number of new and actual customers for each group. Refer
to Item 5 of Form
         20-F and Section III.B.1 of SEC Release No. 33-8350.
9.       Please provide a more detailed explanation of the graphs on page 53.
For example,
         explain what the three different colored lines represent and define
"average spend per
         customer." Also, clarify whether the Global 2000 customers are
included in the average
         spend per customer information. If so, tell us the average spend per
non-Global 2000
         customer for each period presented and explain why you have not
separately provided
         such information.
Components of Statements of Operations, page 53

10.      You disclose that less than 5% of your revenues have been generated
through sales of
         third-party hardware. Please clarify whether this statement refers to
your December 31,
         2017 fiscal year end.
Business
Our Market Opportunity, page 69

11.      You disclose that a May 2018 survey by 451 Research LLC found that 45%
of companies
         do not have security automation and orchestration technologies but
plan to deploy such
         technologies within the next 24 months. Please disclose the number and
types of
         companies surveyed.
Certain Relationships and Related Party Transactions
Rights of Appointment, page 109

12.      Please revise to identify which shareholders have rights of
appointment under your current
         articles of association and which directors have been appointed
pursuant to these rights of
         appointment.
Agreements with Directors and Officers, page 109

13.      You disclose that you have entered into written employment agreements
with your
         executive officers. Please file these employment agreements or tell us
if these agreements
         are not required to be publicly filed in your home country, are not
otherwise publicly
 Reuven Kitov
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         disclosed, and therefore are not filed. See Item 8 of Form F-1 and
Item 601(b)(10)(iii) of
         Regulation S-K.
Note 2. Significant Accounting Policies
f. Accounts Receivable, page F-9

14.      You state that when revenue recognition criteria are not met for a
sales transaction that has
         been billed, you do not recognize either deferred revenues or the
related accounts
         receivable. Please tell us how you considered the guidance in ASC
606-10-45-2 or
         provide any other guidance considered when concluding these amounts
should not be
         recorded on your balance sheet.
j. Revenue Recognition
Nature of Products and Services, page F-11

15.      You state that you determine the standalone selling price of your
software licenses using
         the residual approach. Please tell us which criteria in ASC
606-10-32-34(c) you met when
         determining to use this method. To the extent you have determined the
selling price for
         your software is highly variable, please provide a comprehensive,
quantitative discussion
         of such variability to support your conclusion.
16.      You disclose that your agreements typically provide service level
commitments, whereby
         you could incur penalties for failure to meet maintenance and
professional service
         requirements. Please tell us whether you consider such guarantees to
be variable
         consideration when determining your transaction price. Refer to ASC
606-10-32-5
         through 9 and ASC 606-10-50-20.
Note 7. Deferred Revenues and Deferred Costs, page F-17

17.      Please clarify whether your deferred revenues represent all of your
remaining performance
         obligations. Tell us if all amounts due are billed up-front, and if
not, tell us why unbilled
         amounts have not been included in your remaining performance
obligations disclosure.
         Explain whether your contracts are cancellable, and if so, under what
conditions. Also,
         address the fact that certain deferred revenues are not reflected on
your balance sheet and
         explain how such amounts should be considered in your remaining
performance
         obligations disclosure.
Note 13. Stock Option Plan, page F-22

18.      Please disclose whether your options are granted with an exercise
price equal to fair value
         on the date of grant. If not, disclose the fair value of your ordinary
shares (or a range of
         values) for each period presented as this appears to be a significant
assumption used in
         determining the grant date fair value of the awards. Refer to ASC
718-10-50-2(f)(2).
19.      Please provide us with a breakdown of all options granted to date in
fiscal 2018 and
         include the fair value of the underlying common stock used to value
such awards as
 Reuven Kitov
Tufin Software Technologies Ltd.
December 17, 2018
Page 5
      determined by your board of directors. To the extent there were any
significant
      fluctuations in the fair values from period-to-period, describe for us
the factors that
      contributed to these fluctuations, including any intervening events
within the company or
      changes in your valuation assumptions or methodology.
General

20.   We note that you have included certain graphics in your prospectus.
Please provide us
      with copies of these and any other graphical materials or artwork that
you intend to use in
      your prospectus. Upon review of such materials, we may have further
comments. For
      guidance, consider Question 101.02 of our Securities Act Forms Compliance
and
      Disclosure Interpretations.
21.   Please provide us with copies of all written communications, as defined
in Securities Act
      Rule 405, that you, or anyone authorized to do so on your behalf, present
to potential
      investors in reliance on Securities Act Section 5(d), whether or not they
retain copies of
      the communications.
        You may contact Rebekah Lindsey, Staff Accountant, at (202) 551-3303 or
Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Mitchell
Austin, Staff
Attorney, at (202) 551-3574 or Barbara Jacobs, Assistant Director, at (202)
551-3735 with any
other questions.



                                                            Sincerely,

FirstName LastNameReuven Kitov                              Division of
Corporation Finance
                                                            Office of
Information Technologies
Comapany NameTufin Software Technologies Ltd.
                                                            and Services
December 17, 2018 Page 5
cc:       Colin Diamond, Esq.
FirstName LastName