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
Ernest S. Wechsler
Partner
Phone: 212-715-9211
Fax: 212-715-8000
EWechsler@KRAMERLEVIN.com
October 28, 2009
VIA EDGAR AND FAX
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, 2008 Filed March 31, 2009 Form 6-Ks Filed on February 17, 2009 and May 12, 2009 File No. 333-06208 |
Dear Ms. Collins:
Reference is made to the letter, dated October 16, 2009, to Ms. Varda Sagiv, Chief Financial Officer of BluePhoenix Solutions LTD. (the “Company”), setting forth the comments (the “Comment Letter”) 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, 2008, filed with the Securities and Exchange Commission on March 31, 2009, our response letters dated September 30, 2009 and August 6, 2009 and related filings.
I am hereby requesting, on behalf of the Company, an extension for filing its response to the Comment Letter. The Company will use diligent efforts to provide its response to the Staff by the close of business on November 13, 2009.
Should you have any questions regarding this letter, please do not hesitate to contact me at (212) 715-9211.
Sincerely,
/s/ Ernest S. Wechsler
Ernest S. Wechsler
cc: Melissa Feider
Varda Sagiv
BluePhoenix Solutions LTD.
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