SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4546

       DIVISION OF
CORPORATION FINANCE

December 21 , 2011

  Ms. Heather L. Turner
BRL Law Group LLC
425 Boylston Street, 3
rd Floor
Boston, MA 02116

Re: Brainstorm Cell Therapeutics , Inc.
File No.  333 -61610

Dear. Ms. Turner :

In your  letter dated November 9, 2011, which you provided on beha lf of Brainstorm
Cell Therapeutics Inc.’s management in response to staff comment  on Brainstorm Cell
Therapeutics Inc.’s Form 10- K for the year ended December 31, 2010 filed on March 31,
2011, and as clarified by Ms. Liat Sossover , Chief Financial Officer,  on December 20,
2011, you request ed that the staff not object if Brainstorm Cell Therapeutics :
a) label s as unaudited amounts for periods from Brainstorm Cell Therapeutics
Inc.’s  inception (September 22, 2000) to March 31, 2004 presented in
Brainstorm Cell T herapeutics  Inc.’s  statement of changes in stockholders’
equity /(deficiency) ;
b) includes a footnote to the cumulative column presented on the statement  of
operations that indicates that Brainstorm’s net loss of $163,000 for the period from inception (S eptemb er 22, 2000) through March 31, 2004, which is
classified as discontinued operations,  is unaudited; and
c)  includes a footnote to the cumulative column presented on the statement of cash flows that quantifies the amount of operating, investing and financing cash flows for the period from inception (September 22, 2000) through March 31, 2004, which are classified as cash flows from discontinued operations, indicating such amounts are unaudited.
 Based on the unique facts and circumstances  described in your response, we will not
object  to your request provided that you amend your Form 10- K for the year ended
December 31, 2010 to comply fully with Rule 2- 05 of Regulation S -X.  To this end,
neither the report of your current auditor nor your prior auditor should reference the work
of another auditor unless the report of the other auditor is included in your filing.  To this end, it appears that you will need to request a new report from your current auditor that omits the reference to the work  of auditors whose reports, under your proposal above,
will not be included in Brainstorm Cell Therapeutics Inc.’s filings.

Ms. Heather L. Turner
BRL Law Group LLC
December 21 , 2011
Page 2 of 2

The position described above is based solely on t he information included in your
letter, the clarification provided by Ms. Liat Sos sover, and Brainstorm Cell Therapeutics
management’s assertion that the cumulative statement of operations and cash flow amounts from inception (September 22, 2000) to March 31, 2004 are not material .  New
or different facts could warrant a different concl usion.  If you have any question about
this letter, please call me at 202.551.3516.

Sincerely,
  Todd E. Hardiman
Associate Chief Accountant