|
Wilson Sonsini Goodrich & Rosati Professional Corporation
1700 K Street NW Fifth Floor Washington, D.C. 20006-3817
O: 202.973.8800 F: 866.974.7329 |
September 12, 2023
via electronic filing
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Technology
100 F Street, N.E.
Washington, D.C. 20549
Attention: Laura Veator, Senior Staff Accountant
Stephen Krikorian, Accounting Branch Chief
| Re: | Check Point Software Technologies Ltd. |
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 27, 2023
File No. 000-28584
Dear Ms. Veator and Mr. Krikorian:
On behalf of our client, Check Point Software Technologies Ltd. (“Check Point” or the “Company”), we submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) contained in its letter dated September 7, 2023, relating to the above-referenced Form 20-F for the Company’s fiscal year ended December 31, 2022 filed April 27, 2023.
We have set out the comment from the Staff below in italicized, bold type and have followed the comment with the Company’s response.
In future 20-F filings, please include a discussion addressing the risk that the Company may be deemed an investment company, your reliance on Rule 3a-8, and the consequences if you do not comply with the rule’s conditions.
The Company respectfully advises the Staff that it will include the requested information in its future Form 20-F filings.
*****
AUSTIN BEIJING BOSTON BOULDER BRUSSELS HONG KONG LONDON LOS ANGELES NEW YORK PALO ALTO
SALT LAKE CITY SAN DIEGO SAN FRANCISCO SEATTLE SHANGHAI WASHINGTON, DC WILMINGTON, DE
