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SEC Company Response from BLUE SQUARE ISRAEL — Oct 31, 2005

BLUE SQUARE ISRAEL LTD /ADR/ (CIK 0001016837)
Date: Oct. 31, 2005 · CIK: 0001016837 · Accession: 0001178913-05-001482

AI Filing Summary & Sentiment

File numbers found in text: 333-05024

Referenced dates: September 8, 2005

Date
October 31, 2005
Author
Branch Chief
Form
CORRESP
Company
BLUE SQUARE ISRAEL LTD /ADR/ (CIK 0001016837)

Letter

VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Blue Square-Israel Ltd. Form 20-F for the fiscal year ended December 31, 2004 Filed June 30, 2005 File No. 333-05024

Dear Mr. Ohsiek:

In connection with the comments raised by the Staff in its comment letter dated September 8, 2005 with respect to the Form 20-F of Blue Square-Israel Ltd. (“Blue Square”) for the year ended December 31, 2004, the Company hereby acknowledges the following:

n The Company is responsible for the adequacy and accuracy of the disclosure in this filing;

n Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to filing; and

n 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.

If you have any questions or concerns, please call MR. Emanuel Avner, Vice President and Chief Financial Officer at 972-3-928-2220.

Very
truly yours,
BLUE SQUARE-ISRAEL LTD.

Show Raw Text
CORRESP
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filename1.htm

     CORRESP

Tel
Aviv, October 31, 2005

VIA EDGAR

George F. Ohsiek, Jr.

Branch Chief

Mail Stop 3561

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Blue Square-Israel Ltd.

Form 20-F for the fiscal year ended December 31, 2004

Filed June 30, 2005

File No. 333-05024

Dear Mr. Ohsiek:

In connection with the comments
raised by the Staff in its comment letter dated September 8, 2005 with respect to the Form
20-F of Blue Square-Israel Ltd. (“Blue Square”) for the year ended
December 31, 2004, the Company hereby acknowledges the following:

n
The
Company is responsible for the adequacy and accuracy of the disclosure in this filing;

n
Staff
comments or changes to disclosure in response to staff comments do not foreclose the
Commission from taking any action with respect to filing; and

n
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.

If you have any questions or
concerns, please call MR. Emanuel Avner, Vice President and Chief Financial Officer at
972-3-928-2220.

Very
truly yours,

BLUE SQUARE-ISRAEL LTD.

BY: /S/ Gil Unger
——————————————

Name: Gil Unger
Title: President and Chief Executive

Officer

BY: /S/ Emanuel Avner
——————————————

Name: Emanuel Avner
Title: Vice President and Chief

Financial Officer