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U.S. Securities and Exchange Commission

Securities Exchange Act of 1934
Section 14(a) and Rule 14a-6(a)

October 25, 2018

Response of the Office International Corporate Finance
Division of Corporation Finance

Ross M. Leff
Kirkland & Ellis LLP
601 Lexington Avenue
New York, NY 10022


Teva Pharmaceutical Industries Limited
Incoming letter dated October 24, 2018

Dear Mr. Leff:

We are responding to your request dated October 24, 2018, addressed to Michael Coco.

Based on the facts presented, the Division of Corporation Finance has no objection if Teva Pharmaceutical Industries Limited were to file a definitive proxy statement without filing a preliminary proxy statement for the proposals, as described in your incoming letter, that are required to be submitted for shareholder approval at an annual meeting under the laws of Israel. Foreign issuers organized under the laws of Israel may rely on this letter with respect to the proposals described in your incoming letter.

This position is based on the representations made to the Division in your letter. Any different facts or conditions might require the Division to reach a different conclusion.


Eloise Quarles
Special Counsel,
Office of International Corporate Finance

Incoming Letter:

The Incoming Letter is in Acrobat format.


Modified: 10/26/18