K R A M E R  L E V I N  N A F T A L I S  &  F R A N K E L  LLP

     Tonya M. Smith

     Associate

     Phone   212-715-9373

     Fax   212-715-8321

     tsmith@KRAMERLEVIN.com

   August 23, 2007

VIA EDGAR

Ms. Kathleen Collins

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

  Re: BluePhoenix Solutions Ltd.

        Form 20-F for the Fiscal Year Ended December 31, 2006

    Filed on March 30, 2007

   Form 6-K filed on March 5, 2007

    File No. 333-06208

Dear Ms. Collins:

Reference is made to the letter dated August 2, 2007 to Ms. Varda Sagiv, Chief Financial Officer of BluePhoenix Solutions Ltd. (the “Company”), setting forth the comments of the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”) regarding the above-referenced Form 20-F for the fiscal year ended December 31, 2006 filed with the Securities and Exchange Commission (the “Commission”) on March 30, 2007 and the Form 6-K filed with the Commission on March 5, 2007.

In accordance with our conversations with the Staff, the Company will provide its response to the Staff by September 21, 2007.  The Company sought an extension to provide appropriate time for coordinating between Israeli and U.S. accounting firms and for dealing with the local holiday schedule in Israel.

Should you have any questions regarding this letter, please do not hesitate to contact me at (212) 715-9373.

    Sincerely,

    /s/ Tonya M. Smith

    Tonya M. Smith

cc:           Varda Sagiv, CFO

BluePhoenix Solutions Ltd.