April 30, 2019

Micha Kaufman
Chief Executive Officer
Fiverr International Ltd.
8 Eliezer Kaplan St.
Tel Aviv 6473409, Israel

       Re: Fiverr International Ltd.
           Supplemental Response dated April 24, 2019
           Amendment No. 2 to Draft Registration Statement on Form F-1
           Submitted April 5, 2019
           CIK No. 0001762301

Dear Mr. Kaufman:

       We have reviewed your response and have the following comment. 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to this comment
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. References to prior comments are to comments in our April 18, 2019
letter.

Correspondence Filed April 24, 2019

Notes to Consolidated Financial Statements
p. User funds and user accounts, page F-13

1.     We note your response to prior comment 4. Please address further the
following:

           Provide a thorough analysis supporting your conclusion that the user
funds represent
           assets of the company and cite the specific accounting guidance you
relied upon.
           Tell us how you determined that you have effective control over the
funds. In this
           regard, you appear to be disbursing the funds according to the
agreed terms of service
           between you and your buyers and sellers, and you do not appear to
have the right to
 Micha Kaufman
Fiverr International Ltd.
April 30, 2019
Page 2
           direct the funds to be used at will or for your benefit.
           You state that these funds are kept in separate sub accounts of the
payment provider in
           accordance with applicable regulations. Please tell us if these
funds can be used to
           settle the payment processors obligations in the event of bankruptcy
or liquidation, or
           whether they are considered to be assets that are bankruptcy remote.
           Please tell us why you believe you have an obligation to pay the
seller using your
           assets. Specifically, since funds from the buyer are prepaid, it
does not appear that
           you would be required to use your own assets to settle the
obligation.
           In your March 15, 2019 response letter (comment 3), you state that
orders may be
           cancelled up to 14 days after they are marked as complete. You
further state that
           funds from order cancellations are returned to the buyers' user
accounts balance and
           are available for future purchases on the company's platform, and
you do not
           automatically refund payments made for cancelled orders. Please tell
us whether any
           payments are made to the sellers during this 14 day period.
           To the extent the buyer cancels the order after the seller has been
paid, tell us how you
           are reimbursed from the seller and clarify who is responsible for
reimbursing the
           buyers account if the seller refuses to return the funds.
           You state that the payment flow of the company's platform changed
beginning in 2018
           to better optimize compliance with the applicable state and federal
regulatory
           framework. Please describe further the regulations that prompted
such change.
        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 Matthew
Crispino, Staff Attorney,
at (202) 551-3456 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any
other questions.



                                                              Sincerely,

FirstName LastNameMicha Kaufman                               Division of
Corporation Finance
                                                              Office of
Information Technologies
Comapany NameFiverr International Ltd.
                                                              and Services
April 30, 2019 Page 2
cc:       Marc D. Jaffe
FirstName LastName