February 28, 2019

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
           Response dated February 20, 2019
           CIK No. 0001757399

Dear Mr. Kitov:

      We have reviewed your correspondence dated February 20, 2019 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 February 11,
2019 letter.

Response dated February 20, 2019

Consolidated Financial Statements
Note 2. Significant Accounting Policies
j. Revenue Recognition, page F-11

1.     We note your response to prior comment 2. Please further explain the
following:

           Tell us the nature of the future performance obligations included in
the $25,186
           thousand as of December 31, 2018. In this regard, describe the type
of services that
           you are contractually obligated to provide in the future for which
some level of service
           has not yet been required to be performed;
           Disclosure on page F-11 states that contract payment terms range
between 30 and 120
 Reuven Kitov
Tufin Software Technologies Ltd.
February 28, 2019
Page 2
           days; however, your response indicates payment is due only after
some level of
           services are required to be performed. Explain further what you mean
by "payment is
           due only after some level of services are required to be performed."
Clarify, for
           example, when payment would be due for PCS in year two, when you
determine that
           you have an unconditional right to the consideration, and when you
record a receivable
           for such payments;
           Tell us your consideration of whether these arrangements have a
financing component;
           and
           You state that $1,252 thousands of invoices were due as of December
31, 2017.
           Please clarify whether you believe this should be classified in
accounts receivable. If
           so, tell us how you considered the materiality of such amount to
total accounts
           receivable and current deferred revenue. Alternatively, explain why
such amounts
           should continue to be netted against the contract liabilities.
Note 7. Deferred Revenue and Deferred Costs, page F-18

2.     We note your proposed revised disclosures in response to prior comment
3.
       Please disclose the total amount of remaining performance obligations by
either providing
       quantified information in the text that follows the table or clearly
labeling the line item
       in the table that represents your remaining performance obligations.
        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
February 28, 2019 Page 2
cc:       Colin Diamond, Esq.
FirstName LastName