September 11, 2025

Eliran Glazer
Chief Financial Officer
monday.com Ltd.
6 Yitzhak Sadeh Street
Tel Aviv, 6777506 Israel

        Re: monday.com Ltd.
            Form 20-F for the Year Ended December 31, 2024
            File No. 001-40461
Dear Eliran Glazer:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 20-F for the Year Ended December 31, 2024
Operating Results
Comparison of the Years Ended December 31, 2024 and 2023, page 60

1.     Please revise to provide a more substantive analysis of the reasons for
changes in
       revenue during the periods presented. Your discussion should address the
impact of
       changes in pricing, new or expanded product lines, and to the extent
possible, quantify
       increases driven by existing customers separate from increases
attributable to new
       customers. We note, for example, that the Q4 2024 and Q2 2025
shareholder letters
       provided on your website include metrics about customer growth
associated with your
       CRM, service and dev products that provide additional insights not
addressed in
       MD&A. Similarly, in your February 10, 2025 earnings call, management
       quantified the impact of pricing on 2024 results and provided an
estimate of expected
       future pricing impacts but neither are included in your MD&A for the
year ended
       December 31, 2024. Refer to Item 303 of Regulation S-K.
 September 11, 2025
Page 2
Liquidity and Capital Resources, page 64

2.     We note that you have a significant amount of cash on hand as of
December 31, 2024.
       Please revise to provide a more substantive discussion of your material
cash
       requirements from known and other obligations both in the short-term and
separately
       in the long-term (beyond the next 12 months). As part of this analysis,
identify any
       known trends, demands, commitments, events or uncertainties that are
reasonably
       likely to materially impact your liquidity and capital resources. For
example, we note
       from your Q4 2024 investor presentation that your future plans include
an expansion
       of your core work product lines. Additionally, in your August 11, 2025
earnings call,
       management discussed investing in mondayDB. Your revised disclosures
should
       address the timeline and expected cost of any known or anticipated
investments along
       with the anticipated impact on your capital resources and liquidity.
Consolidated Financial Statements
Note 16. Segment Reporting, page F-48

3.     We note your disclosure indicating that you manage your business on the
basis of one
       reportable segment and unit. Based upon comments made by management
during your
       February 10, 2025 earnings call, it appears that discrete financial
information below
       the consolidated level is both available to and reviewed by management.
Please tell us
       how you considered ASC 280-10-50 in determining your operating and
reportable
       segments. To the extent that you have aggregated multiple operating
segments into a
       single reportable segment, please also tell us your basis for doing so.
4.     Please refer to ASC 280-10-50-40 and tell us how you considered
disclosing revenues
       from external customers for each of your four main products: work
management,
       CRM, dev and service. We note a recent announcement in your Q2 2025
shareholder
       letter that the CRM product reached $100 million in ARR. As such, it
appears that
       there is sufficient financial information available to report revenues
from external
       customers by product.

        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.

       Please contact Lisa Etheredge at 202-551-3424 or Robert Littlepage at
202-551-3361
with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology