September 20, 2024

Chaim Lebovits
Chief Executive Officer
Brainstorm Cell Therapeutics, Inc.
1325 Avenue of Americas, 28th Floor
New York, NY 10019

       Re: Brainstorm Cell Therapeutics, Inc.
           Registration Statement on Form S-3
           Filed September 17, 2024
           File No. 333-282172
Dear Chaim Lebovits:

     We have conducted a limited review of your registration statement and have
the following
comment.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a comment applies to your facts
and circumstances
or do not believe an amendment is appropriate, please tell us why in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to this letter, we may have additional comments.

Registration Statement on Form S-3
Risk Factors, page 4

1.     Please revise the Risk Factors section of this Form S-3 to discuss the
risk that the
       company may fail to regain compliance with the continued listing
requirements of
       Nasdaq, which may result in the company's common stock being delisted
and negatively
       impact the price and liquidity of the company's common stock. We note
this risk is
       discussed in the company's Form 10-Q for the quarterly period ended June
30, 2024, filed
       on August 14, 2024.
 September 20, 2024
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Daniel Crawford at 202-551-7767 or Laura Crotty at
202-551-7614 with
any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:   Faith Charles, Esq.