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April 9, 2021

Or Offer
Chief Executive Officer
Similarweb Ltd.
121 Menachem Begin Rd.
Tel Aviv-Yafo 6701203, Israel

Re: Similarweb Ltd.
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted March 26,
2021
CIK No. 0001842731

Dear Mr. Offer:

We have reviewed your amended draft 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 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 these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
March 18, 2021 letter.

Amendment No. 1 to Draft Registration Statement

Prospectus Summary, page 1

1. In response to prior
comment 1, you state that the company generated in excess of
$100,000 ARR from 16 of
the Fortune 500 customers out of the 31 customers in
December 31, 2020. To
provide appropriate context regarding the customers you
highlight in the
prospectus summary, please provide this information in the filing.
Business
Data Collection, page 109

2. We note your response
to prior comment 14. Please revise to disclose, as you do in your
Or Offer
Similarweb Ltd.
April 9, 2021
Page 2
response, that you do not acquire a significant portion of your data
from a single data
partner or group of data partners.
Audited Consolidated Financial Statements
2. Summary of significant accounting policies
Revenue recognition, page F-10

3. You disclose on page 143 that you granted Myraid (a related party) a
non-exclusive
license to your cloud-based solutions. You also disclose on page 21 that
it is important
that your customers renew or expand their licenses with you. Your
revenue recognition
policy makes no reference to licenses. Please supplementally describe
the circumstances
under which you grant licenses to customers (for example, on a
standalone basis, in
conjunction with a SaaS subscription and/or in connection with a data
supply agreement).
Please tell us if the licenses you grant are term or perpetual licenses
and if you combine
licenses with SaaS subscriptions into a single performance obligation.
Please also
quantify for us any license revenue recognized during the periods
presented.
You may contact Lisa Etheredge, Senior Staff Accountant, at (202)
551-3424 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Jeff
Kauten, Staff
Attorney, at (202) 551-3447 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other
questions.



Sincerely,
FirstName LastNameOr Offer
Division of
Corporation Finance
Comapany NameSimilarweb Ltd.
Office of
Technology
April 9, 2021 Page 2
cc: Nicole Brookshire, Esq.
FirstName LastName