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                               August 4, 2022

       Sharon Carmel
       Chief Executive Officer
       Beamr Imaging Ltd.
       10 HaManofim Street
       Herzeliya, 4672561, Israel

                                                        Re: Beamr Imaging Ltd.
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed July 12, 2022
                                                            File No. 333-262904

       Dear Mr. Carmel:

             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.

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

       Recent Developments, page 2

   1.                                                   We note that you have
delayed the anticipated timeline for the release of the integrated
                                                        video optimization
engine, cloud-based SaaS platform, and the commercial launch of the
                                                        HW-Accelerated Content
Adaptive Encoding solution. To the extent material, provide
                                                        additional context so
investors can understand the reasons for, and assess the viability of,
                                                        the revised timeline
for the development and launch of your solutions.
 Sharon Carmel
FirstName  LastNameSharon Carmel
Beamr Imaging  Ltd.
Comapany
August     NameBeamr Imaging Ltd.
       4, 2022
August
Page 2 4, 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Impact of Invasion of Ukraine, page 58

2.       We note your disclosure that the potential impact of the conflict and
any resulting bans,
         sanctions and boycotts on companies doing business in Russia is
currently uncertain and
         that the conflict could have a material adverse effect on your
operations, results of
         operations, financial condition, liquidity and business outlook.
Please expand your
         discussion to address any impact resulting from the reaction of your
investors, employees,
         customers, and/or other stakeholders to any action or inaction arising
from or relating to
         the invasion, including the payment of taxes to the Russian
Federation. Additionally,
         address whether there is a possibility that Russia or another
government could
         nationalize your assets or operations in Russia and quantify the
potential impact to your
         financial statements.
3.       Provide detailed disclosure regarding your stated intentions to
implement a business
         continuity plan in order to address risks related to the conflict on
your personnel,
         operations and product development, including with respect to
alternative payment
         solutions for personnel in Russia and relocating certain personnel to
territories outside
         Russia.
4.       Please describe the extent and nature of the role of the board of
directors in overseeing
         risks related to Russia   s invasion of Ukraine, including risks
related to cybersecurity,
         sanctions, employees based in affected regions, and risks associated
with ongoing or
         halted operations or investments in affected regions.
Exhibit 23.1, page 1

5.       Your auditor refers to their report dated July 12, 2022 in the
consent. However, their
         report on page F-3 is dated February 22, 2022 (except for Note 16D and
Note 16E, where
         the date is July 12, 2022). Please have your auditor advise or revise
this discrepancy
         accordingly.
       You may contact Ryan Rohn, Senior Staff Accountant, at (202) 551-3739 or
Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Priscilla Dao, Staff
Attorney, at (202) 551-5997 or Joshua Shainess, Legal Branch Chief, at (202)
551-7951 with any
other questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Technology
cc:      Eyal Peled