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                             August 7, 2020

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

                                                        Re: PainReform Ltd.
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed August 5,
2020
                                                            File No. 333-239576

       Dear Mr. Hazum:

              We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to the comment, we may have additional comments.

       Form F-1/A filed on August 5, 2020

       Selected Financial Data, page 7

   1.                                                   Given the expected
conversion of all your outstanding preferred shares, convertible debt
                                                        and convertible notes
immediately before the closing of this offering, please provide pro
                                                        forma EPS data here and
on page 42 per Rule 11-01(a)(8) of Regulation S-X.
 Eli Hazum
PainReform Ltd.
August 7, 2020
Page 2

       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
August 7, 2020 Page 2
cc:       Steven Glusband, Esq.
FirstName LastName