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
October 25, 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 October 11, 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 Company’s response letter, dated September 21, 2007, relating to 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 November 2, 2007.
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.
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