United States securities and exchange commission logo
April 26, 2023
Jacob (Kobi) Marinka
Chief Executive Officer
Arbe Robotics Ltd.
107 HaHashmonaim St.
Tel Aviv-Yafo, Israel
Re: Arbe Robotics Ltd.
Form 20-F for the
Fiscal Year Ended December 31, 2022
Filed March 22,
2023
File No. 001-40884
Dear Jacob (Kobi) Marinka:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. In our comment, we ask you
to provide us with
information so we may better understand your disclosure.
Please respond to this comment within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 15. Controls and Procedures, page 85
1. Please file an amended
Form 20-F to include management's report on internal control over
financial reporting.
Refer to Item 15(b) of Form 20-F and Question 2 of the Frequently
Asked Questions for
Exemptive Order on Management's Report on Internal Control over
Financial Reporting
available at: https://www.sec.gov/divisions/corpfin/faq012105.htm.
In closing, 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.
Jacob (Kobi) Marinka
Arbe Robotics Ltd.
April 26, 2023
Page 2
You may contact Joyce Sweeney, Senior Staff Accountant, at 202-551-3449
or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 with any questions.
FirstName LastNameJacob (Kobi) Marinka Sincerely,
Comapany NameArbe Robotics Ltd.
Division of
Corporation Finance
April 26, 2023 Page 2 Office of Technology
FirstName LastName