SecProbe.io

April 5, 2019
Ron Babecoff
Chief Executive Officer and Director
BiondVax Pharmaceuticals Ltd.
Jerusalem BioPark, 2nd floor
Hadassah Ein Kerem Campus
Jerusalem, Israel
Re:BiondVax Pharmaceuticals Ltd.
Registration Statement on Form F-1
Filed March 25, 2019
File No. 333-230484
Dear Dr. Babecoff:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  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 by amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form F-1 Filed March 25, 2019
Financial Statements, page F-1
1.Please revise to provide updated audited financial statements.  Refer to Item 4(a) of Form
F-1 and Part I, Item 8.A.4 of Form 20-F.
Exhibits
2.We note that Section 7.6 of the Deposit Agreement and Section 23 of Exhibit A includes a
waiver of jury trial provision with respect to any suit, action or proceeding against the
company and/or the depositary directly or indirectly.  Please revise the Deposit Agreement

 FirstName LastNameRon Babecoff
 Comapany NameBiondVax Pharmaceuticals Ltd.
 April 5, 2019 Page 2
 FirstName LastName
Ron Babecoff
BiondVax Pharmaceuticals Ltd.
April 5, 2019
Page 2
to state that, by agreeing to the provision, investors will not be deemed to have waived the
company's compliance with the federal securities laws and the rules and regulations
thereunder.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Jeffrey Gabor at 202-551-2544 or Suzanne Hayes at 202-551-3675 if
you have any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc:       Tammy Zoppo, Esq.