United States securities and exchange commission logo August 13, 2020 Gerald Commissiong Chief Executive Officer Todos Medical Ltd. 1 Hamada Street Rehovot, Israel Re: Todos Medical Ltd. Registration Statement of Form F-1 Filed August 11, 2020 Amendment No. 1 to Registration Statement of Form F-1 Filed August 12, 2020 File No. 333-244414 Dear Mr. Commissiong: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Chris Edwards at (202) 551-6761 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Carl M. Sherer