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                              February 8, 2021

       Gilad Shany
       Chief Executive Officer
       ION Acquisition Corp 2 Ltd.
       89 Medinat Hayehudim Street
       Herzliya 4676672, Israel

                                                        Re: ION Acquisition
Corp 2 Ltd.
                                                            Registration
Statement on Form S-1
                                                            Filed January 26,
2021
                                                            File No. 333-252440

       Dear Mr. Shany:

              We have reviewed your registration statement and have the
following comment. In our
       comment, 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 comment applies 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 this comment, we may have additional comments.

       Form S-1 filed January 26, 2021

       Exhibits

   1.                                                   We note the legality
opinion filed as exhibit 5.2 only covers 23 million units and
                                                        references each unit
consisting of one common stock and one-fifth of a warrant.
                                                        Similarly, we note that
Exhibit 5.1 references each unit consisting of one ordinary share
                                                        and one-third of a
redeemable warrant. Please update to cover the entire amount being
                                                        registered, as
disclosed on the registration statement cover page, and update the fractional
                                                        warrant.
               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.
 Gilad Shany
ION Acquisition Corp 2 Ltd.
February 8, 2021
Page 2

       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 Eric Mcphee at 202-551-3693 or Isaac Esquivel at
202-551-3395 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Pam Howell at 202-551-3357 or David Link at 202-551-3356 with any other
questions.



                                                           Sincerely,
FirstName LastNameGilad Shany
                                                           Division of
Corporation Finance
Comapany NameION Acquisition Corp 2 Ltd.
                                                           Office of Real
Estate & Construction
February 8, 2021 Page 2
cc:       Joel Rubinstein
FirstName LastName