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                      December 11, 2023

       Asaf Berenstin
       Chief Financial Officer
       Formula Systems (1985) Ltd.
       Yahadut Canada 1 Street
       Or Yehuda 6037501, Israel

                                                        Re: Formula Systems 
(1985) Ltd.
                                                            Form 20-F for the 
Fiscal Year Ended December 31, 2022
                                                            File No. 000-29442

       Dear Asaf Berenstin:

              We have completed our review of your filing. 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.



                                                                                
                      Sincerely,

                                                                                
                      Division of Corporation Finance
                                                                                
                      Office of Technology
       cc:                                              Guy Bernstein