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
February 7, 2008
VIA FACSIMILE
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Barbara C. Jacobs, Assistant Director
Re: | BluePhoenix Solutions Ltd. Form F-3, filed January 7, 2008 File No. 333-148504 |
Dear Ms. Jacobs:
On behalf of our client, BluePhoenix Solutions Ltd. (the “Company”), we provide the following clarification to the letter from the Company to the Securities and Exchange Commission, dated February 5, 2008. The Company’s disclosure in Item 15 in future Annual Reports on Form 20-F will be revised as follows:
During the period covered by this report, there were no changes in our internal control over financial reporting that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
Please let us know if you have any further questions or comments regarding this matter.
Regards,
/s/ Abraham Safdie
Abraham Safdie
1177 Avenue of the Americas New York NY 10036-2714 Phone 212.715.9100 Fax 212.715.8000 www.kramerlevin.com
also at 47 Avenue Hoche 75008 Paris France