SecProbe.io

October 26, 2011

Via E-mail
Liat Sossover Chief Financial Officer
Brainstorm Cell Therapeutics, Inc.
605 Third Avenue, 34
th Floor
New York, NY 10158

Re: Brainstorm Cell Therapeutics, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2010
 Filed March 31, 2011
File No. 0-54365

Dear Mr. Sossover:

We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to  other portions of your document.
  Please respond to this letter within ten business days by providing us the requested
information, amending your filing or by advi sing us when you will provide the requested
response.  If you do not believe the comment applie s 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 any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.

Report of Independent Registered Public Accounting Firm, page 29

1. The audit report of Brightman Algamor Zohar & Co. references the report of another
auditor for the financial statements through December 31, 2007.  Please amend your
filing to include Brightman Algamor Zohar & Co.’s report as reissued by them as
required by Rule 2-05 of  Regulation S-X.

We urge all persons who are responsible for th e 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 requir e.  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:

Liat Sossover
Brainstorm Cell Therapeutics, Inc.
October 26, 2011
Page 2

  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.

You may contact Vanessa Robert son, Staff Accountant, at (202) 551-3649 or Mary Mast,
Senior Staff Accountant, at ( 202) 551-3613 if you have any questi ons 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