SecProbe.io

June 10, 2014

Via E-mail
Mr. Eyal Desheh
Execu tive Vice President and Chief Financial Officer
Teva Pharmaceutical Industries Ltd.
5 Base l Street
P.O. Box 3190
Petach Tivka 4951033 Israel

Re: Teva  Pharmaceutical  Industries Ltd.
Form 20-F for the Fiscal Year Ended December 31, 2013
Filed February 10, 2014
File No . 001-16174

Dear M r. Desheh :

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

Please respond to this letter within 10 business days by providing the requested
information or by advising  us when you will provide the requested response.  If you do not
believe the comment applies to your facts and circumstances, please tell us why in your
response.  Please furnish us a letter on EDGAR under the form type label CORRESP that keys
your response  to our comment.

After reviewing the information pr ovided, we may have additional comments and/or
request that you amend your filing.

Principal Accountant Fees and Services, page 133

1. You disclose that you paid fees to your auditors for general guidance on a ccounting issues.
Please tell us the nature of the guidance you received and why you do not believe the
services constituted a prohibited service under Rule 2 -01(c)(4)(i)  of Regulation S -X.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing  include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating  to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment, please provide  a written statement from the company
acknowledging that:

 the company is responsible for th e adequacy and accuracy of the disclosure in the filing;

Mr. Eyal Desheh
Teva Pharmaceutical Industries, Ltd.
June 10, 2014
Page 2

  staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Christine Torney , Staff Accountant, at (202) 551 -3652 or  Mary Mast ,
Senior Staff Accountant , at (202) 551 -3613 if you have questions regarding the comment .  In this
regard, do not hesitate to contact me at (202) 551 -3679.

Sincerely,

/s/ Jim B.  Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant