TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo December 19, 2022 Zvi Schreiber Chief Executive Officer Freightos Ltd HaPo el 1 Derech Agudat Sport HaPo el Jerusalem, Israel 9695102 Re: Freightos Ltd Registration Statement on Form F-4 Filed December 9, 2022 File No. 333-268742 Dear Zvi Schreiber: We have reviewed your 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. Form F-4 filed December 9, 2022 Proposal One - The Business Combination Proposal Background of the Business Combination, page 98 1. We note your revised disclosure in response to comment 2. Please identify the peer group of public companies that Gesher's management considered in arriving at the initial estimate of the enterprise value range. With respect to the discounted cash flow analysis, disclose the discount rates and the basis for Gesher's management selection of those rates. 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. Zvi Schreiber Freightos Ltd December 19, 2022 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 Sondra Snyder, Staff Accountant, at 202-551-3332 or Robert Babula, Staff Accountant, at 202-551-3339 if you have questions regarding comments on the financial statements and related matters. Please contact Anuja Majmudar, Staff Attorney, at 202- 551- 3844 or Loan Lauren Nguyen, Legal Branch Chief, at 202-551-3642 with any other questions. Sincerely, FirstName LastNameZvi Schreiber Division of Corporation Finance Comapany NameFreightos Ltd Office of Energy & Transportation December 19, 2022 Page 2 cc: Stephen Alicanti FirstName LastName