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Teva Pharmaceutical Industries Ltd.

Registration Form Aug 13, 2020

7082_rns_2020-08-13_e45cf421-49aa-4d26-ad1f-bb2f5ce0a2fc.pdf

Registration Form

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Teva Pharmaceutical Industries Limited 5 Basel Street P.O. Box 3190 Petach Tikva, 4951033 Israel

August 13, 2020

Via EDGAR Submission

Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549

Re Teva Pharmaceutical Industries Limited Registration Statement on Form S-4 (File No. 333-241010)

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 Form S-4 (SEC File No. 333-241010) (the "Registration Statement"), to 9:00 a.m., Eastern Time, on August 17, 2020, 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 August 13, 2020 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/ Eli Kalif
Name: Eli Kalif
Title: Executive Vice President and Chief Financial
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/ Tomer Amitai

Name: Tomer Amitai 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/ Tomer Amitai

Name: Tomer Amitai Title: Managing Director

cc: Ross M. Leff Kirkland & Ellis LLP

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