SecProbe.io

CORRESP
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August 16, 2017

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Cellect Biotechnology Ltd.

Registration Statement on Form F-3

File No. 333-219614

VIA EDGAR

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities
Act of 1933, as amended, Cellect Biotechnology Ltd. (the “Registrant”) hereby respectfully requests that the
effectiveness of the Registration Statement on Form F-3 (File No. 333-219614) of the Registrant (the “Registration Statement”)
be accelerated so that it will be declared effective at 4:30 p.m., Eastern Time, on August 17, 2017 or as soon thereafter as may
be practicable.

The Registrant hereby confirms that it
is aware of its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended,
as they relate to the proposed offering of the securities specified in the Registration Statement. The Registrant hereby acknowledges
that:

 ● should
                                         the Securities and Exchange Commission (the “Commission”) or the staff, acting
                                         pursuant to delegated authority, declare the Registration Statement effective, it does
                                         not foreclose the Commission from taking any action with respect to the Registration
                                         Statement;

 ● the action of the Commission or the staff, acting pursuant to delegated authority, in declaring
                                the Registration Statement effective, does not relieve the Registrant from its full responsibility
                                for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the Registrant may not assert staff comments
    and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal
    securities laws of the United States.

The undersigned respectfully requests that
it be notified of the effectiveness of the Registration Statement by telephone call to our counsel, McDermott Will & Emery
LLP, by calling Gary Emmanuel at (212) 547-5541. The Company hereby authorizes Mr. Emmanuel to orally modify or withdraw this
request for acceleration.

Please also provide a copy of the Commission’s
order declaring the Registration Statement effective to Mr. Emmanuel via email to gemmanuel@mwe.com or facsimile to (212) 547-5444
and via mail at 340 Madison Avenue, New York, NY 10173.

    Very truly yours,

    CELLECT BIOTECHNOLOGY LTD.

    By:
    /s/ Shai Yarkoni

    Name: Shai Yarkoni

    Title:   Chief Executive Officer

cc: Gary Emmanuel (McDermott Will & Emery LLP)