K R A M E R L E V I N N A F T A L I S & F R A N K E L LLP
Tonya M. Smith
Associate
Phone 212-715-9373
Fax 212-715-8321
tsmith@KRAMERLEVIN.com
August 23, 2007
VIA EDGAR
Ms. Kathleen Collins
Accounting Branch Chief
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Re: BluePhoenix Solutions Ltd.
Form 20-F for the Fiscal Year Ended December 31, 2006
Filed on March 30, 2007
Form 6-K filed on March 5, 2007
File No. 333-06208
Dear Ms. Collins:
Reference is made to the letter dated August 2, 2007 to Ms. Varda Sagiv, Chief Financial Officer of BluePhoenix Solutions Ltd. (the “Company”), setting forth the comments of the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”) regarding the above-referenced Form 20-F for the fiscal year ended December 31, 2006 filed with the Securities and Exchange Commission (the “Commission”) on March 30, 2007 and the Form 6-K filed with the Commission on March 5, 2007.
In accordance with our conversations with the Staff, the Company will provide its response to the Staff by September 21, 2007. The Company sought an extension to provide appropriate time for coordinating between Israeli and U.S. accounting firms and for dealing with the local holiday schedule in Israel.
Should you have any questions regarding this letter, please do not hesitate to contact me at (212) 715-9373.
Sincerely,
/s/ Tonya M. Smith
Tonya M. Smith
cc: Varda Sagiv, CFO
BluePhoenix Solutions Ltd.