My Size, Inc. — Capital/Financing Update 2007

Aug 28, 2007

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TopSpin Medical, Inc. 2 Yodfat Street, Third Floor North Industrial Area Lod 71291 Israel

August 28, 2007

VIA EDGAR

Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549

Re: TopSpin Medical, Inc. Registration Statement on Form SB-2 Commission File No. 333-144472

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, TopSpin Medical, Inc. (the “ Company ”) hereby requests that the effective date of the Company’s Registration Statement on Form SB-2, Commission File No. 333-144472 (as amended, the “ Registration Statement ”) be accelerated so that the Registration Statement will become effective at 5:30 p.m. on Friday, September 7, 2007 or as soon thereafter as reasonably practicable.

In connection with this acceleration request, the Company acknowledges that:

| • | should the Commission or the staff of the Commission, 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
Company from its full responsibility for the adequacy and accuracy of the
disclosure in the Registration Statement; and |
| • | the Company may not assert the 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. |

Please direct any questions regarding this request or the Registration Statement to Robert B. Murphy at (202) 220-1454 or David Yoon at (215) 981-4543.

Very truly yours, TopSpin Medical, Inc.
By:	/s/ Eyal Kolka
	Eyal Kolka
	Chief Financial Officer

Folio /Folio