SecProbe.io

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                  [LETTERHEAD OF WILLKIE FARR & GALLAGHER LLP]

VIA EDGAR
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July 16, 2008

Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.  20549
Attn:  Jim B. Rosenberg, Senior Assistant Chief Accountant
       Division of Corporation Finance

Re:  Teva Pharmaceutical Industries Limited
     Form 20-F for the Fiscal Year Ended December 31, 2007
     Filed February 29, 2008
     File No. 000-16174
     ------------------

Dear Mr. Rosenberg:

     On behalf of Teva Pharmaceutical Industries Limited ("Teva" or the
"Company"), set forth below is Teva's response to the further comment of the
staff (the "Staff") of the Securities and Exchange Commission ("SEC")
transmitted orally by Ms. Kei Ino to me initially on July 2, 2008 and then
raised again, following our further response letter of July 10, 2008, on July
15, 2008. For your convenience, set forth below is what I believe to be an
accurate transcript of this follow-up comment in italics, followed by Teva's
response thereto.

Form 20-F for the Fiscal Year Ended December 31, 2007
-----------------------------------------------------

Item 5:  Operating and Financial Review and Prospects
-----------------------------------------------------

Results of Operations
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Other Income Statement Line Items
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Securities and Exchange Commission
July 16, 2008
Page 2

Revenue Recognition and Sales Reserves and Allowances, page 62
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1.   Regarding our previous comment number 2, please revise your disclosure to
     clarify that rebates represent a majority of the rebates and other sales
     reserves and allowances and that other sales reserves and allowances
     represented 6% of the provision balance and of the total provision balance
     for the year.

In response to this comment, in its 2008 Form 20-F, Teva will state that (1)
rebates represented a majority of the rebates and other sales reserves and
allowances for the year and (2) sales reserves and allowances other than rebates
represented __% of the reserve balance and __% of the total provision for the
year.
                                   * * * * * *

     In submitting this response to the Staff's comments, on behalf of Teva, we
acknowledge that:

          o    the Company is responsible for the adequacy and accuracy of the
               disclosure in its filings with the SEC;

          o    Staff comments or changes to disclosure in response to Staff
               comments do not foreclose the SEC from taking any action with
               respect to the filings; and

          o    the Company may not assert Staff comments as a defense in any
               proceeding initiated by the SEC or any person under the federal
               securities laws of the United States.

     Should any member of the Staff have any questions or comments concerning
this letter, please do not hesitate to call me at (212) 728-8592 or Peter Jakes
of this office at (212) 728-8230.

Very truly yours,

/s/ Jeffrey S. Hochman

Jeffrey S. Hochman

cc:  Bryan Pitko (SEC)
     Don Abbott (SEC)
     Kei Ino (SEC)
     Eyal Desheh (Teva)
     Dan S. Suesskind (Teva)
     Uzi Karniel (Teva)
     Peter H. Jakes (Willkie Farr)

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