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                                                                                                April 23, 2007

Dan S. Suesskind
Chief Financial Officer
Teva Pharmaceutical Industries Limited
5 Basel Street
P.O. Box 3190
Petach Tikva 49131, Israel

Re: Teva Pharmaceutical Industries Limited
 Form 20-F for Fiscal Year Ended December 31, 2006
 File No. 000-16174

Dear Mr. Suesskind:

We have limited our review of your filing to the issue we have addressed in our
comment.  In our comment, we ask you to provi de us with information so we may better
understand your disclosure.  Please be as detail ed as necessary in your explanation.  After
reviewing this information, we may raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comment or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 20-F – December 31, 2006

Consolidated Financial Statements, page F-1

Notes To Consolidated Financial Statements, page F-10

Note 4 – Goodwill and Intangible Assets, page F-23

b.  Intangible assets, page F-24

1. Please provide to us in disclosure type  format a discussion of the significant
products acquired that resulted in your product rights intangible assets.  Include
the amount allocated to each major product or product class of this intangible.

Dan S. Suesskind
Teva Pharmaceutical Industries Limited
April 23, 2007 Page 2
Also provide us proposed revisions to your management’s discussion and analysis that quantifies the impact that these va rious products acquire d had on your current
period results such as revenues.

*    *    *    *

Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please furnish a letter that keys your responses to our
comment and provide the request ed information.  Detailed le tters greatly facilitate our
review.  You should furnish the letter to  us via EDGAR under the form type label
CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings to be certain that the filings include all information required under the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comment, please provide , in your letter, a
statement from the company acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

You may contact James Pe klenk, Staff Accountant, at (202) 551-3661, or Jim
Atkinson, Accounting Branch Chief, at (202)  551-3674 if you have questions regarding
the comment.  In this regard, do not he sitate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief Accountant