United States securities and exchange commission logo 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