SecProbe.io

November 14 , 2012

Via E -mail
Dr. Yuval Cohen
President
Morria Biopharmaceuticals PLC
53 Davies Street
London W1K 5JH
United Kingdom

Re: Morria Biopharmaceuticals PLC
Amendment No. 2 to Registration Statement on Form 20 -F
Filed October 29 , 2012
  File No. 000 -54749

Dear Dr. Cohen:

We have reviewed your amended registration statement and we have the following
additional comment s.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you wil l provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response .

After reviewing the next  amendment to your registration statement and the information
you provide in response to th ese comment s, we may have additional comments.

Interim Consolidated Financial Statements (Unaudited)
General

1. Please re -number the pages to the unaudited interim financial statements so they do not
duplicate the same page numbers in the audited financial statements.

2. It appears that the column headings on pages F -4 and F -6 label on ly 2011 as unaudited.
Please label all three columns as unaudited or label the entire financial statement as
unaudited.

Notes to Consolidated Financial Statements
General
3. Please label the header to all pages of the interim notes as unaudited.

Dr. Yuval Cohen
Morria Biopharmaceuticals PLC
November 14 , 2012
Page 2

 Note 3 .  Unaudited Interim Consolidated Financial Statements, page F -9

4. Please revise to include a statement in the notes to the financial statements disclosing that
the interim financial statements reflect all adjustments, which are, in the opinion of
managemen t, necessary to a fair statement of the results for the interim periods presented
as required by Rule 10 -01(b)(8) of Regulation S -X.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includ es the information the Securities 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 adequac y 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 filing;

 staff comments or ch anges 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 und er the federal securities laws of the United States.

You may contact Ja mes Peklenk at (202) 551 -3661 or Donald Abbott at (202) 551 -3608
if you have questions regarding comments on the financial statements and related matters.
Please contact Scot Foley at (2020) 551 -3383, Jennifer Riegel at (202) 551 -3575 or me at (202)
551-3715 with any other questions.

Sincerely,

 /s/ Jennifer Riegel for

Jeffrey Riedler
Assistant Director

cc: Jeffrey  Schultz, Esq.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
666 Third Avenue
New York,  NY 10017