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                             June 16, 2020

       Eli Hazum
       Acting Chief Executive Officer
       PainReform Ltd.
       60C Medinat Hayehudim
       Herzliya, 4676670, Israel

                                                        Re: PainReform Ltd.
                                                            Amendment No. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted June 2,
2020
                                                            CIK No. 0001801834

       Dear Mr. Hazum:

              We have reviewed your amended draft registration statement and
have the following
       comment. In our comment, we may ask you to provide us with information
so we may better
       understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comment applies to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to the
comment and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form F-1 submitted June 2, 2020

       Prospectus Summary
       Overview, page 1

   1.                                                   We note your response
to comment 1, which we reissue in part. Your disclosure continues
                                                        to state your
conclusion that your proprietary extended release drug-delivery system
                                                        prolongs the in vivo
activity of active pharmaceutical ingredients, thus increasing the
                                                        therapeutic window for
patient treatment. You may summarize or describe data from
                                                        clinical trials without
drawing conclusions with respect to efficacy. You may also describe
                                                        what your product
candidate is designed to do. Please revise this statement to remove
                                                        your conclusion.
 Eli Hazum
PainReform Ltd.
June 16, 2020
Page 2
      Please also remove all statements that imply that your product has been
or will be found to
      be safe. As illustrative examples, we note the following:

          PRF-110 was well tolerated and demonstrated an excellent safety
profile. (page 54)
          We have amassed an extensive safety toxicology portfolio for
PRF-110... (page 54)

       You may contact Ameen Hamady at 202-551-3891 or Al Pavot at 202-551-3738
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alan Campbell at 202-551-4224 or Christine Westbrook at 202-551-5019
with any other
questions.



                                                           Sincerely,
FirstName LastNameEli Hazum
                                                           Division of
Corporation Finance
Comapany NamePainReform Ltd.
                                                           Office of Life
Sciences
June 16, 2020 Page 2
cc:       Steven Glusband, Esq.
FirstName LastName