November 24, 2020
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Division of Corporation Finance, Office of Technology
VIA EDGAR
| Re: | Formula Systems (1985) Ltd. (the “Company”) |
| Form 20-F for the Fiscal Year Ended December 31, 2019 | |
| Filed June 29, 2020 | |
| File No. 000-29442 |
Dear Madams and Sirs:
We have received the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) concerning the above-referenced filing that were provided to the Company by the Staff in its letter dated November 10, 2020 (the “Comment Letter”).
As mentioned on the telephone by our external legal counsel, Jonathan M. Nathan of Meitar Law Offices, on November 23, 2020, we are unable to respond to the Comment Letter within the initial ten business day period provided for in the Comment Letter. This was due to the illness with COVID-19 of a key officer of the Company who is responsible for leading the Company’s internal processes for responding. We expect to file our response letter within an additional ten business day period following the initial due date, i.e., by Wednesday, December 9, 2020.
We appreciate your attention to this letter. Should you wish to discuss this letter or the Comment Letter at any time, please do not hesitate to contact our legal counsel, Meitar Law Offices (Mike Rimon, Adv. at 011-972-3-610-3621 or Jonathan M. Nathan, Adv. at 011-972-3-610-3182).
| Sincerely, | |
| /s/ Asaf Berenstin | |
| Asaf Berenstin | |
| Chief Financial Officer | |
| Formula Systems (1985) Ltd. | |
| cc: | Megan Akst, Senior Staff Accountant |
| Christine Dietz, Senior Staff Accountant | |
| (Securities and Exchange Commission) | |
| Mike Rimon, Adv. | |
| Jonathan M. Nathan, Adv. | |
| (Meitar Law Offices) |