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SEC Company Response from M-SYSTEMS FLASH DISK PIONEERS LTD (CIK 0000895361) — Oct 27, 2005

M-SYSTEMS FLASH DISK PIONEERS LTD (CIK 0000895361)
Date: Oct. 27, 2005 · CIK: 0000895361 · Accession: 0000895361-05-000049

AI Filing Summary & Sentiment

File numbers found in text: 333-126774

Date
October 26, 2005
Author
Branch Chief - Legal
Form
CORRESP
Company
M-SYSTEMS FLASH DISK PIONEERS LTD (CIK 0000895361)

Letter

Securities and Exchange Commission Washington, D.C. 20549 Re: M-Systems Flash Disk Pioneers Ltd. (the "Company") Registration Statement on Form F-3/A (File Number 333-126774)

Dear Mr. Shuman:

Pursuant to Rule 461 of the Securities Act of 1933, the undersigned registrant hereby requests acceleration of the effectiveness date of the above-captioned registration statement to Thursday, October 27, 2005 at 5:00 p.m., EST, or as soon as practicable thereafter.

The Company hereby acknowledges the following:

1. Should the Securities and Exchange Commission (the "Commission") or the staff thereof, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

2. The action of the Commission or the staff thereof, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

3. The Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very Truly Yours,
M-Systems Flash Disk Pioneers
Ltd.

Show Raw Text
CORRESP
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filename1.htm

G85453

M-SYSTEMS FLASH DISK PIONEERS LTD.

7 ATIR YEDA STREET

KFAR SABA, ISRAEL 44425

October 26, 2005

Mr. Mark Shuman

Branch Chief - Legal

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:          M-Systems Flash Disk Pioneers Ltd. (the
"Company")

Registration Statement on Form
F-3/A

(File Number 333-126774)

Dear Mr. Shuman:

Pursuant to Rule 461 of the
Securities Act of 1933, the undersigned registrant hereby requests acceleration
of the effectiveness date of the above-captioned registration statement to
Thursday, October 27, 2005 at 5:00 p.m., EST, or as soon as practicable
thereafter.

The Company hereby acknowledges
the following:

1.             Should the
Securities and Exchange Commission (the "Commission") or the staff thereof,
acting pursuant to delegated authority, declare the filing effective, it does
not foreclose the Commission from taking any action with respect to the filing;

2.             The action of the
Commission or the staff thereof, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the Company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing;
and

3.             The Company may
not assert staff comments and the declaration of effectiveness as a defense in
any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Very Truly Yours,

M-Systems Flash Disk Pioneers
Ltd.

By:   /s/
Ronit Maor________

Name:  Ronit Maor

Title:  Chief
Financial Officer

__1__