United States securities and exchange commission logo

                            February 3, 2023

       Ran Daniel
       Chief Financial Officer
       Nano-X Imaging Ltd.
       Communication Center
       Neve Ilan , Israel 9085000

                                                        Re: Nano-X Imaging Ltd.
                                                            Form 20-F for
Fiscal Year Ended December 31, 2021
                                                            Filed May 2, 2022
                                                            Response Letter
Dated February 1, 2023
                                                            File No. 001-39461

       Dear Ran Daniel:

               We have reviewed your February 1, 2023 response to our comment
letter and have the
       following comment. In our comment, we may ask you to provide us with
information so we may
       better understand your disclosure.

              Please respond to this comment 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 our
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this comment, we may have
       comments. Unless we note otherwise, our reference to a prior comment are
to comments in our
       January 18, 2023 letter.

       Form 20-F for Fiscal Year Ended December 31, 2021

       Item 5. Operating and Financial Review and Prospects
       E. Critical Accounting Estimates, page 90

   1.                                                   We note your response
to comment 2. Regarding the draft disclosures provided, please
                                                        address the following:
                                                            Clarify that the
amount of goodwill assigned to the AI solutions reporting unit at the
                                                            interim testing
date was $51.2 million and that $14.3 million was recognized as an
                                                            impairment charged
based on the testing results.
                                                            Expand your
discussion of the discounted cash flow model used to estimate the fair
                                                            value of your AI
solutions reporting unit to state when you have assumed that the
                                                            business will be
generating material revenues, gross profit and positive operating
 Ran Daniel
Nano-X Imaging Ltd.
February 3, 2023
Page 2
              cash flows to support the remaining $36.9 million of goodwill as
of December 31,

       You may contact Tracey Houser at 202-551-3736 or Terence O'Brien at
202-551-3355, if
you have questions regarding comments on the financial statements and related

FirstName LastNameRan Daniel
                                                             Division of
Corporation Finance
Comapany NameNano-X Imaging Ltd.
                                                             Office of
Industrial Applications and
February 3, 2023 Page 2                                      Services
FirstName LastName