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October 15,2010
VIA FAX AND FEDERAL EXPRESS
Mr. Kevin Vaugh
Division of Corporate Finance
U.S. Securties and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Vuance Ltd. (the "Companv")
Form 20-F for the vear ended December 31. 2009
Filed Julv 23. 2010
File No. 1-33668
Dear Mr. Vaughn:
We write in response to your letter, dated September 17,2010 (the "Letter") (a copy of which is annexed hereto for convenience) regarding the Company's
Form 20-F for the year ended December 31, 2009 (the "Form 20-F"). We have reviewed your comments set fort in the Letter and respond to each in turn as
set forth below. .
I. Response to Comment No. I.
Mr. Mickey Ben Harsh curently serves in the capacity of the Company's principal financial officer. Future fiings by the Company will clearly
indicate the identity of the principal financial offcer of the Company, or person performing similar functions.
On July 22, 2010, the filing date of the Company's Form 20-F, Mr. Eyal Tuchman, formerly the Company's Chief Executive Offcer, served in the
capacity ofthe Company's principal financial offcer. Mr. Tuchman executed the certification pursuant to Section 302(a) of the Sarbanes-Oxley Act of
2002, annexed as Exhibit 12.2 to the Form 20-F (the "Certification"). Pursuant to the Certification, Mr. Tuchman attested that as of the fiing date, he
was responsible for establishing and maintaining disclosure controls and procedures, and internal control over financial reporting for the Company, and
that he had evaluated the effectiveness of the Company's disclosure controls and procedures, and presented in the Form 20-F management's
conclusions regarding the effectiveness of the disclosure controls and procedures for the period reported therein. Future filings by the Company wil
clarifY the conclusions of the principal financial offcer of the Company, or person performing similar functions.

2. Resoonse to Comment NO.2.
The Company reported an allowance for doubtful accounts in the amount of $3,470,000 (the "Allowance") for the year ended December 3 1,2009.
Approximately $1,200,000 ofthe Allowance is attibuted to a debt owed to SuperCom Slovakia A.S. ("SuDerCom"), the Company's sixty-six percent
(66%) owned subsidiar. The debt arose out of that certin Agreement on Delivery of Technology, Cooperation and Services, between SuperCom and
the Ministr ofInterior of the Slovak Republic. The debt has been outstanding as of March 1999. SuperCom obtained an arbitral award to collect on
the debt, and to date, the Company has sought to enforce the arbitral award. For a full description of this matter please reference Note I I :c.2 on page
140 of the Form 20-F.
Approximately $2, I 32,870 of the Allowance is attibuted to a debt owed to the Company arising out of that certain Contract No. 10/82, between the
Company and the Ministry ofInternal Affairs of Ukraine. The debt has been outstanding as of September 2003. Curently, hearings are scheduled
during the months of November, 2010 and January, 20 I I, in the Central District Court ofIsrael in connection with this dispute. For a full description of
this matter please reference Note 11 :c. I on page 139 of the Form 20-F.
The allowance for doubtful accounts is determined with respect to specific amounts the Company has determined to be doubtful of collection. In
determining the allowance for doubtful accounts, the Company considers, among other things,- its past experience with such customers and the
information available regarding such customers. After the Company has implemented its best efforts to collect the specific amounts the Company has
determined to be doubtful of collection, including without limitation by exhausting available legal process, such specific amounts wil be written-off
3. Resoonse to Comment NO.3.
The Company does not provide for waranty costs at the time that revenue is recognized because, based on historical experience, such waranty costs
have not been materiaL. Future fiings by the Company will clarifY that management's estimates of warranty costs are based primarily on historical
experience and that such waranty costs are not materiaL.
4. Resoonse to Comment No.4.
The Company will ensure that if revenues from customers attibuted to an individual foreign countr within the geographic market of Europe are
material to the Company, then the Company will revise all future fiings consistent with paragraph 280-10-50-4 I (a) of the FASB Accounting Standards
Codification.
2

5. Response to Comment NO.5.
The Company wil revise all future fiings to disclose tangible long-lived assets by geographic area, consistent with paragraph 280-10-55-23 of the
FASB Accounting Stadards Codification.
6. Response to Comment No.6.
The Company's Chief Executive Offcer is the Company's principal executive offcer. Future fiings by the Company will clarifY the same.
On July 22, 2010, the fiing date of the Company's Form 20-F, Mr. Tuchman served in the capacity of the Company's principal financial offcer. Mr.
Tuchman executed the Certification pursuant to Section 302(a) of the Sarbanes-Oxley Act of 2002, anexed as Exhibit 12.2 to the Form 20-F. Future
filings by the Company wil clarifY the conclusions of the principal financial offcer of the Company, or person performing similar functions.
We trust that you will find the foregoing responsive to your comments. We acknowledge that: the Company is responsible for the adequacy and accuracy of the
disclosure in the filing; staff comments or changes to disclosures in response to staff comments do not foreclose the Securities and Exchange 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 Securities and
Exchange Commission or any person under the federal securities laws of the United States.
If you have any further comments or questions, please do not hesitate to contact me directly at (414) 301-9435, extension 1075.
Very trly yours,
û(O,Lf~t:
Ron Peer, Chief Executive Offcer
Vuance Ltd.
Enc.
3

SEC Inquiry Letter
4

UNITED STA TES
SECURITIES AND EXCHANGE COMMISSION
100 F Street. N.E.
Washington, D.C. 20549
FAX TRANSMITTAL
PLEASE DELIVER THE FOLLOWING PAGES TO:
Name: Mr. Ron Pear
Organization: Vuance Ltd.
Telecopier Number: 972-9-8890820
Total Number of Pages, Including Cover Sheet: 4
Document: Comment letter on review of Form 20-F fied July 23, 2010
FROM: David Burton
Telephone Number: 202-551-3626
Fax Number: 703-813-6985
If you do not receive all pages, please telephone the above number for assistance.
NOTE: THIS DOCUMENT MAY CONTAIN PRIVILEGED AND NONPUBLIC INFORMATION. IT IS INTENDED ONLY FOR THE USE OF
THE INDIVIDUAL OR ENTITY NAMED ABOVE, AND OTHERS WHO SPECIFICALLY HAVE BEEN AUTHORIZED TO RECEIVE IT. If you
are not the intended recipient of this facsimile, or the agent responsible for delivering it to the intended recipient, you hereby are notified that any
review, dissemination, distribution, or copying of this communication strictly is prohibited. If you have received this communication in error, please
notify us immediately by telephone and return the original to the above address by regular postal service without making a copy. Thank you for your
cooperation

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
September 17,2010
Via Facsimile and U.S. Mail
Mr. Ron Peer
Chief Executive Offcer
Vuance Ltd.
Sagid House "Ha Sharon Industrial Park"
P.O.B 5039
Qadima, Israel 60920
Re: Vuance Ltd.
Form 20-F for the year ended December 31,2009
Filed July 23, 2010
File No. 1-33668
Dear Mr. Peer:
We have reviewed your fiing and have the following comments. We have limited our review to only your financial statements and related disclosures
and do not intend to expand our review to other portions of your documents. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information or by advising us when you wil provide the requested
response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may have additional comments.
Form 20-F for the vear ended December 31 2009
Item 15. Controls and Procedures oage 104
Disclosure controls and orocedures. oage 104
I. We note your reference to "Chief Executive Offcer" in the first paragraph concluding that your disclosure controls and procedures, as of December
3 1,2009, were not effective. We note a similar reference in the first sentence of the second paragraph. Item 15 of Form 20-F requires you to disclose
the conclusion of your principal executive offcer and orincioal financial officer regarding the effectiveness of your disclosure controls and
procedures. Please tell us who is serving in the capacity of principal financial officer and why such reference was not included in the disclosure.
Revise future fiings as appropriate.

Mr. Ron Peer
Vuace Ltd.
September 17,2010
Page 2
Note 2. Significant Accounting Policies page 121
(g). Allowance for Doubtful Accounts oage 123
2. We note that your allowance for doubtful accounts represents approximately 80% of your gross accounts receivable as of December 31, 2009. Please
explain to us the circumstances that have resulted in your allowance for doubtful accounts being so high in relation to your total accounts receivable.
Describe the age ofthe receivables to which the allowance for doubtful accounts relates. Finally, explain the procedures you perform to monitor the
allowance for doubtful accounts and to write-off uncollectible receivables.
(0). Revenue Recognition. oage 125
3. We note your disclosure on page 126 regarding warty costs. Please explain to us how your policy of not recording warranty costs at the time of
sale of products complies with U.S. GAAP. In this regard, if tre, you could revise future filings to state that management's estimates of warranty
costs are based primarily on historical experience and that such costs are not materiaL.
Note 16. Segments Maior Customers and Geograohic Information oage F- I 55
4. We note your disclosure of revenues by geographic segment. If revenues from customers attributed to an individual foreign country within the
Europe geographic market are material, please revise future fiings to disclose those revenues separately. Refer to paragraph 280-1 0-50-41 (a) of the
F ASB Accounting Standards Codification.
5. We note your disclosure of long-lived assets by geographic ara includes goodwill and intangible assets. Please revise future fiings to disclose
tangible long-lived assets by geographic area. Refer to the guidance in paragraph 280-10-55-23 of the FASB Accounting Standards Codification.
Exhibits 12.1 and 12.2
6. Rule 13a-14(a) requires you to provide a signed certification from each of your principal executive offcer and your principal financial offcer, or
persons performing similar functions. It is not clear to us whether you have complied with this guidance. Specifically, we note that Exhibit 12. I is
signed by your "chief executive offcer." Also, it is not clear to us if you have provided a signed certification from your principal financial offcer.
Please address the following:
. Please tell us and revise future fiings as appropriate to clarifY, if true, that your chief executive offcer is your principal executive offcer.
. Please tell us the individual who is your principal financial officer. Explain to us how the certificaions provided in the Form 20- F comply
with the requirement that you provide a signed certification from your principal financial officer or person performing similar functions.
Revise future filings as appropriate to clearly identifY the individual signing as your principal financial offcer.

Mr. Ron Peer
Vuance Ltd.
September 17,2010
Page 3
We urge all persons who are responsible for the ac~uracy and adequacy of the disclosure in the fiing to be certain that the fiing includes the
information the Securties Exchange Act of 1934 and all applicable Exchange Act rules require. 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 comments, please provide a written statement from the company acknowledging that:
. the company is responsible for the adequacy and accuracy of the disclosure in the fiing;
. staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taing any action with respect
to the fiing; 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 David Burton, Staff Accountant at (202) 551-3626 or me at (202) 551-3643 if you have questions regarding these comments. In this
regard, do not hesitate to contact Martin James, Senior Assistant Chief Accountant at (202) 551 -3671.
Sincerely,

Kevin L. Vaughn
Accounting Branch ChiefStaff signature redacted.