SecProbe.io

March 19 , 2014

Via E -mail
Yaky Yanay
Executive Vice President, Chief
Financial Officer and Secretary
Pluristem Therapeutics, Inc.
MATAM Advanced Technology Park
Building No. 5
Haifa, Israel 31905

Re: Pluristem Therapeutics, Inc.
Form 10 -K for t he Fiscal year Ended June 30, 2013
Filed September 11 , 2013
Response dated February 19, 2014
File No. 001 -31392

Dear Mr. Yanay :

We have reviewed your February 19, 2014  response to our February  4, 2014  comment
letter and have t he following additional comment .

Please respond to this letter within ten  business days by providing the requested
infor mation or by advising us when you will provide the requested response .  If you do  not
believe our comment  applies  to your facts and circu mstances , please tell us why in your
response.

After revie wing the infor mation you provide  in response to this  comment, we may have
additio nal co mments.

Item 1. Business
Ongoing Research and Development Plans, pag e 6

1. We note your response to our prior comment 1 and your position that the royalty rate
represents confidential information.   However, you should still disclose the royalty rate
within a range of 10%, e.g., single digits, teens, etc.   This is true even i f the exact
percentage rate has been redacted pursuant to a grant of confidential
treatment.   Additionally, please note that under the confidential treatment rule, we have
the authority to reconsider our action in the future with respect to grants of confi dential
treatment.  Please include your proposed disclosure in a supplemental response that also
includes the full proposed disclosure from your letter dated February 19, 2014 in
response to comment 1.

Yaky Yanay
Pluristem Therapeutics, Inc.
March 19 , 2014
Page 2

We urge all persons who are respons ible for the accuracy and adequacy of the disclosure
in the filings to be certain that the filings include  the in formation the Securities E xchange Act of
1934 and all applicable Exchange Act rules require.  Since the compa ny and its man agement are
in poss ession of  all facts relating  to a compa ny’s disclosur e, they are responsible for the accuracy
and adequacy of the  disclosur es they have made.

In responding to our comment , please provide a written 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 comment s as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States .

Please contact Austin Stephenson at (202) 551 -3192, John Krug at (202) 551 -3862  or me
at (202) 551 -3715 with any  questions.

Sincerely,

 /s/ Bryan J. Pitko for

 Jeffrey P. Riedler
Assistant Director