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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE      Mail Stop 3030

         A u g u s t  1 3 ,  2 0 0 9
  VIA U.S. MAIL and FACSIMILE: (972) (4) 604-8300

  Ms. Mira Rosenzweig Chief Financial Officer Camtek, Ltd. Ramat Gavriel Industrial Zone P.O. Box 544 Migdal Ha’Emek, Israel

Re: Camtek, Ltd.
 Forms 20-F for Fiscal Years Ended December 31, 2006, 2007 and 2008
Filed on June 29, 2007, June 30, 2008 and April 8, 2009
          File No. 000-30664
Dear Ms. Rosenzweig:
We have reviewed your filings and have the following comments.  Where
indicated, we think you should revise your future  filings in response to these comments.
If you disagree, we will consider your explanation as to why our comment is inapplicable
or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure.  Af ter reviewing this information, we may or
may not 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 filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Ms. Mira Rosenzweig
Camtek, Ltd.
August 13, 2009 Page 2    Form 20-F for the Year Ended December 31, 2006 and

Form 20-F for the Year Ended December 31, 2007
Item 18.  Consolidated Financial Statements
 1. Tell us where you have presented re-issued  audit reports from the predecessor
auditor in the referenced Fo rms 20-F.  As set forth in paragraphs 1 through 3 of
Item 8A of Form 20-F, the filing should present audit reports covering each of the
annual periods required to be presented in your document.
 Form 20-F for the Year Ended December 31, 2008

Item 18.  Consolidated Financial Statements
Consolidated Statements of Cash Flows, page F-8
 2. Please tell us about and in future filing pl ease make disclosure about the nature of
and business reasons for the transfer  of inventory to fixed assets.
 Note 2 – Significant Accounting Policies, page F-9

G.  Inventories

3. You disclose that estimates of invent ory impairment could vary significantly
either favorably or unfavorably.  In light of your disclosure, please tell us and in
future filings clarify how your policy fo r inventory impairment considers the
guidance from SAB Topic 5-BB.  Under that guidance inventory impairment
charges are permanent reductio ns of inventory cost.

4. As a related matter, in future periods pl ease disclose the impact on gross margin
from sales of previously impaired inventory in MD&A, if significant.
 T.  Derivative Instruments

 5. You disclose that the results of derivative transactions related to foreign currencies are included in financial expenses.  In future filings please make a more comprehensive accounting policy disc losure about derivatives.  In that
regard, clarify whether fore ign exchange derivatives are marked-to-market.  Also
clarify how you determine fair value of ope n contracts at period end and disclose
the level in the fair value hierarchy where that fair value falls.

Ms. Mira Rosenzweig
Camtek, Ltd.
August 13, 2009 Page 3   Note 5 - Inventories, page F-16

 6. We note that you have classified $22 milli on of inventory as a long-term asset
because you do not expect to “convert or consume” this inventory in 2009.  To assist us in understanding your accounting rationale, please respond to the following:

• Describe the components of the i nventory classified as long-term.
• Describe how you measured the po rtion classified as long-term.
• Describe the program you adopted to consume the long-term inventory referred to in your disclosure and de scribe the significant assumptions on
which your plan is based.
• Tell us the expected peri od of liquidation of the long-term inventory and the
basis for your expectations.
• Tell us how you considered the potentia l for technical ob solescence of the
long-term inventory.  In that regar d, we see a Risk Factor on page 10
indicating that tec hnology in your markets rapidly evolves.
• Tell us how you determined that the long-term inventory is recoverable.  That is, tell us how you have applied the rule of  pricing inventories at lower of cost
or market as that notion is set forth in FA SB ASC 330-10-35.
 Note 13- Commitments and Contingencies, page F-21

C.  Factoring of financial assets
 7. You disclose that you account for the factored receivables under SFAS 140.  In future filings please expand to describe how you account for factored receivables.
That is, describe how you apply SFAS 140 in your circumstances.
 D. Litigation

 8. We note that as a result of a trial a ju ry awarded damages of $7 million in your
case with Rudolph Technologies, Inc.  We also see that there is no provision for
losses in this matter because you believe that  the plaintiffs will not ultimately be
successful.  Please tell us how you cons idered the guidance from FASB ASC 450-
20-25-1 through 450-20-25-5 in assessing th e appropriate accounting for this
matter.  In that regard, please explai n why you believe there is no probable and
reasonably estimable loss.

*****

Ms. Mira Rosenzweig
Camtek, Ltd. August 13, 2009 Page 4
 As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Pl ease furnish a cover letter that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.
   We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at 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 comments, please provide, in writing, a statement from the company acknowledging that:  ‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
‚ 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.

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 filing or in response to our comments on your filing.

 You may contact Jong Hwang at (202) 551-3327 or me at (202) 551-3605 if you
have questions about these comments.  In this  regard, please do not hesitate to contact
Brian Cascio, Branch Chief, at ( 202) 551-3676 with any other questions.

 Sincerely,

Gary Todd Senior Review Accountant