<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                            December 20, 2024

Amihay Hadad
Chief Executive Officer
Viewbix Inc.
3 Hanehoshet St.
Building B, 7th floor,
Tel Aviv, Israel 5268104

       Re: Viewbix Inc.
           Form 10-K for the Year Ended December 31, 2023
           Filed March 25, 2024
           Form 10-Q for the Quarter Ended September 30, 2024
           Filed November 19, 2024
           File No. 000-15746
Dear Amihay Hadad:

       We have limited our review of your filings 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 10-K for the Year Ended December 31, 2023
Liquidity and Capital Resources, page 52

1.     We note your discussion of cash flows repeats line items in the
statement of cash
       flows, but does not provide investors with insight as to underlying
reasons for
       changes. In future filings, please revise and expand your disclosure to
provide such
       insight in accordance with Item 303(b) of Regulation S-K.
Item 9A Controls and Procedures, page 56

2.     We note that your disclosure controls and procedures were not effective
as of
       December 31, 2022, and that there appears to be no representation on
page 55 about
       the effectiveness of Disclosure Controls and Procedures as of December
31, 2023. In
       future filings, please provide management's assessment regarding the
effectiveness of
 December 20, 2024
Page 2

       both the Company's disclosure controls and procedures and internal
control over
       financial reporting as of the end of the most recent fiscal year in
accordance with Item
       9A of Form 10-K.


Form 10-Q for the Quarter Ended September 30. 2024
Financial Statements
Notes to Interim Condensed Consolidated Financial Statements
Note 5: Goodwill and Intangible Assets, Net, page 19

3.     Tell us how you considered the need to evaluate the recovery of your
customer
       relations and technology intangible assets as of September 30, 2024 in
light of the
       adverse impacts due to industry technological changes and your loss of
customers.
       Refer to ASC 350-30-35-14 and ASC 360-10-35-21.
Management's Discussion and Analysis
Results of Operations, page 42

4.     We note continuing material decline of Gix Media Search Platform
revenues. In
       future filings, quantify direct model search referral and revenue losses
due to changes
       and updates to browser technologies. Please also quantify how the number
of indirect
       model searches received from third party strategic partners has changed
between
       periods. Address known trends and uncertainties that are expected to
have a material
       impact on these sources of revenues. Refer to Item 303(c) of Regulation
S-K.
        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 Joseph Kempf at 202-551-3352 or Lisa Haynes Etheredge at
202-551-
3424 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
</TEXT>
</DOCUMENT>
