Tel Aviv, October 31, 2005
VIA EDGAR
George F. Ohsiek, Jr.
Branch Chief
Mail Stop 3561
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Blue Square-Israel Ltd. Form 20-F for the fiscal year ended December 31, 2004 Filed June 30, 2005 File No. 333-05024 |
Dear Mr. Ohsiek:
In connection with the comments raised by the Staff in its comment letter dated September 8, 2005 with respect to the Form 20-F of Blue Square-Israel Ltd.(“Blue Square”) for the year ended December 31, 2004, the Company hereby acknowledges the following:
| n | The Company is responsible for the adequacy and accuracy of the disclosure in this filing; |
| n | Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to filing; and |
| n | The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
If you have any questions or concerns, please call MR. Emanuel Avner, Vice President and Chief Financial Officer at 972-3-928-2220.
| Very truly yours, |
| BLUE SQUARE-ISRAEL LTD. |
| BY: /S/ Gil Unger —————————————— Name: Gil Unger Title: President and Chief Executive Officer | BY: /S/ Emanuel Avner —————————————— Name: Emanuel Avner Title: Vice President and Chief Financial Officer |
