February 19, 2019


Via E-Mail

Richard Anslow
Ellenoff Grossman & Schole LLP
1345 Avenue of the Americas
New York, NY 10105

       Re:    MICT, Inc.
              Schedule TO-T filed on February 5, 2019
              Filed by BNN Technology PLC
              File No. 5-86541

Dear Mr. Anslow:

        The Office of Mergers and Acquisitions has conducted a limited review
of the filing
listed above. Our comments follow. All defined terms have the same meaning as
in the Offer to
Purchase included as Exhibit 99(a)(1)(A) to the Schedule TO-T.

       Please respond to this letter by revising your filing, by providing the
requested
information, or by advising us when you will provide the requested response. 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 any amendment to your filing and the information you
provide in
response to these comments, we may have additional comments.

General

   1. Please provide your supplemental analysis as to why this tender offer is
not the first step
      in a going private transaction. In this regard, we note that affiliates
of the bidder own
      14% of MICT and are tendering for an additional 20% of the outstanding
common
      shares. The disclosure in the Offer to Purchase states that Nasdaq "may
consider
      delisting the Shares if certain conditions are not met." In addition, GFH
will acquire all
      Shares of MICT after the Offer under the terms of the more comprehensive
Acquisition
      Agreement. We may have additional comments after reviewing your analysis.

   2. See our comment above with reference to the broader Acquisition Agreement
transaction,
      of which this Offer is only a part. Given that the Offer is required
under the terms of the
 Richard Anslow, Esq.
Ellenoff Grossman & Schole LLP
October 19, 2019
Page 2


       Agreement and that GFH will ultimately acquire MICT after the Offer,
tell us why
       additional bidders are not required on the Schedule TO-T (including but
not limited to
       GFH). Please note that if additional bidders are added, each must
individually satisfy the
       disclosure and dissemination requirements of Schedule TO.

   3. Consider adding a chart or diagram that shows the post-Acquisition
structure of the
      entities that are parties to the Acquisition Agreement, whether "before
and after" or
      showing the multiple steps of the contemplated acquisition transactions.

   4. Expand the disclosure in the Offer to Purchase to more thoroughly explain
why the
      bidder is conducting this Offer and how it fits into the broader
transactions contemplated
      by the Acquisition Agreement. We note in this regard that the Background
of the Offer
      section (Section 11) in the Offer to Purchase is currently only two
sentences long.
      Similarly, Section 12 (Plans for MICT) does not appear to describe the
subsequent
      acquisition of MICT by GFH which we understand is contemplated by the
Acquisition
      Agreement.

        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contact me at (202) 551- 3263 with any questions about these comments.


                                                    Sincerely,

                                                    /s/ Christina Chalk

                                                    Christina Chalk
                                                    Senior Special Counsel
                                                    Office of Mergers and
Acquisitions