November 25, 2024

Noah Hershcoviz
Chief Executive Officer
Hub Cyber Security Ltd.
2 Kaplan St.
Tel Aviv, Israel 6473403

       Re: Hub Cyber Security Ltd.
           Amendment No. 1 to Form 20-F for the Year Ended December 31, 2023
           Response dated October 22, 2024
           File No. 001-41634
Dear Noah Hershcoviz:

        We have reviewed your October 22, 2024 response to our comment letter 
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.
Unless we note otherwise, any references to prior comments are to comments in 
our
September 18, 2024 letter.

Form 20-F/A for the Year Ended December 31, 2023
Item 5. Operating and Financial Review and Prospects
Results of Operations, page 84

1.     We note your response to prior comment 1. While your revised disclosures 
make
       reference to the decline in revenues as attributed to "two customers," 
you have not
       provided any context as to how material these customers were to your 
business and
       the impact that the loss of these customers is expected to have on your 
operating
       results for the upcoming year. Additionally, while you quantify the 
decrease in cost of
       revenues for each segment, your analysis does not provide any insight 
into the reasons
       for these decreases and the extent to which they are expected to 
continue. Please show
       us how you will revise your future filings accordingly.
 November 25, 2024
Page 2
Audited Financial Statements
Note 1 - General
f. Internal investigations, page F-16

2.     We note your response to prior comment 3. Please tell us if the Company 
was aware
       of the misappropriation allegations on February 2, 2023 when you filed 
the Form 6-K
       announcing the resignation of Mr. Moshe as Chief Executive Officer. If 
so, please
       also tell us if the allegations were among the reasons for Mr. Moshe's 
resignation.

        Please contact Lisa Etheredge at 202-551-3424 or Robert Littlepage at 
202-551-3361
if you have questions regarding comments on the financial statements and 
related matters.



                                                          Sincerely,

                                                          Division of 
Corporation Finance
                                                          Office of Technology