March 14, 2019

Reuven Kitov
Chief Executive Officer
Tufin Software Technologies Ltd.
5 Shoham Street
Ramat-Gan 52521, Israel

       Re: Tufin Software Technologies Ltd.
           Registration Statement on Form F-1
           Filed March 6, 2019
           File No. 333-230109

Dear Mr. Kitov:

       We have reviewed your registration statement and have the following
comments. In
some of our comments, we may ask you to provide us with information so we may
better
understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form F-1 Filed March 6, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Factors Affecting Our Performance, page 52

1.     You state on pages 12 and 53 that sales to Global 2000 customers were
66% of total
       revenue in fiscal 2018. Please revise to clarify whether this measure
excludes
       maintenance renewals, similar to your discussion of Global 2000 revenues
for fiscal years
       2016 to 2018 in your prospectus summary.
 Reuven Kitov
FirstName LastNameReuven Kitov
Tufin Software Technologies Ltd.
Comapany2019
March 14, NameTufin Software Technologies Ltd.
March 14, 2019 Page 2
Page 2
FirstName LastName
Results of Operation
Comparison of the Years Ended December 31, 2017 and 2018, page 58

2.       You state that total revenue growth, as well as product and
maintenance support revenue
         growth, was due primarily to increased sales to new and existing
customers. Please revise
         to quantify the amount of revenue growth from new versus existing
customers so readers
         can assess the relative contribution of each of these factors. In
addition, you attribute the
         increase in cost of sales to an increase in support and professional
service personnel.
         Please disclose the number of employees in your support and
professional service
         department for each period presented. Refer to Item 5.A of Form 20-F
and Section III.D
         of SEC Release No. 33-6835.
Liquidity and Capital Resources, page 62

3.       Please include a discussion of the underlying reasons for the changes
in cash flows
         provided by or used in operating activities and ensure you address the
factors that
         impacted the $4.4 million net increase in operating assets and
liabilities. Refer to Item
         5.B of Form 20-F and Section IV.B.1 of SEC Release No. 33-8350.
Contractual Obligations , page 64

4.       Please include a discussion of the long-term lease agreement for
additional office space
         and parking that you entered into in fiscal 2019. Refer to Section
IV.A of SEC Release
         33-8350.
Notes to Consolidated Financial Statements
Note 13. Stock Option Plan , page F-25

5.       We will consider further your response to comment 19 to our December
17, 2018 letter
         when we receive your analysis of the difference between the fair value
of the underlying
         common stock as of your recent valuation dates to the midpoint of your
IPO price
         range. This reconciliation should describe significant intervening
events within the
         company and changes in assumptions as well as weighting and selection
of valuation
         methodologies employed that explain the changes in the fair value of
your common
         stock.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Reuven Kitov
Tufin Software Technologies Ltd.
March 14, 2019
Page 3

        You may contact Rebekah Lindsey, Staff Accountant at (202) 551-3303 or
Kathleen
Collins, Accounting Branch Chief at (202) 551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Mitchell
Austin, Staff Attorney
at (202) 551-3574 or Barbara Jacobs, Assistant Director at (202) 551-3735 with
any other
questions.



                                                           Sincerely,

FirstName LastNameReuven Kitov                             Division of
Corporation Finance
                                                           Office of
Information Technologies
Comapany NameTufin Software Technologies Ltd.
                                                           and Services
March 14, 2019 Page 3
cc:       Colin Diamond, Esq.
FirstName LastName