Teva Pharmaceutical Industries Limited
5 Basel Street
P.O. Box 3190
Petach Tikva, 4951033 Israel
April 16, 2018
Via EDGAR Submission
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-3561
Re: | Teva Pharmaceutical Industries Limited |
Registration Statement on FormS-4 (File No. 333-224102)
Ladies and Gentlemen:
Pursuant to Rule 461 of the Securities Act of 1933, as amended (the “Act”), Teva Pharmaceutical Industries Limited (the “Company”), Teva Pharmaceutical Finance Netherlands II B.V. and Teva Pharmaceutical Finance Netherlands III B.V. (collectively, the “Registrants”) hereby request acceleration of the effective date of its Registration Statement on FormS-4 (SEC FileNo. 333-224102) (the “Registration Statement”), to 8:00 a.m., Eastern Time, on Thursday, April 19, 2018, or as soon thereafter as possible. The Registrants hereby acknowledge their responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed exchange offer of the securities specified in the Registration Statement.
U.S. Securities and Exchange Commission
April 16, 2018
Page 2
Please contact Ross M. Leff of Kirkland & Ellis LLP, special counsel to the Company, at (212)446-4947, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.
Sincerely, | ||
Teva Pharmaceutical Industries Limited | ||
By: | /s/ Deborah Griffin | |
Name: | Deborah Griffin | |
Title: | Senior Vice President and Chief Accounting Officer |
Teva Pharmaceutical Finance Netherlands II B.V. | ||
By: | Teva Pharmaceuticals Europe B.V., its Managing Director |
By: | /s/ David Vrhovec | |
Name: | David Vrhovec | |
Title: | Managing Director |
By: | /s/ John Nason | |
Name: | John Nason | |
Title: | Managing Director |
Teva Pharmaceutical Finance Netherlands III B.V. | ||
By: | Teva Pharmaceuticals Europe B.V., its Managing Director |
By: | /s/ David Vrhovec | |
Name: | David Vrhovec | |
Title: | Managing Director |
By: | /s/ John Nason | |
Name: | John Nason | |
Title: | Managing Director |
cc: | Ross M. Leff |
Kirkland & Ellis LLP