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<SEC-DOCUMENT>0000000000-05-040154.txt : 20060913
<SEC-HEADER>0000000000-05-040154.hdr.sgml : 20060913
<ACCEPTANCE-DATETIME>20050804104003
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-05-040154
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20050804

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			NUR MACROPRINTERS LTD
		CENTRAL INDEX KEY:			0000946394
		STANDARD INDUSTRIAL CLASSIFICATION:	PRINTING TRADES MACHINERY & EQUIPMENT [3555]
		IRS NUMBER:				000000000
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		5 DAVID NAVON STREET
		STREET 2:		MOSHAV MAGSHIMIM
		CITY:			PETAH-TIKVA ISRAEL
		STATE:			L3
		ZIP:			00000
		BUSINESS PHONE:		01197239087676

	MAIL ADDRESS:	
		STREET 1:		P O BOX 8440
		STREET 2:		MOSHAV MAGSHIMIM
		CITY:			ISRAEL
		STATE:			L3
		ZIP:			00000

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	NUR ADVANCED TECHNOLOGIES LTD
		DATE OF NAME CHANGE:	19950607
PUBLIC REFERENCE ACCESSION NUMBER:		0001178913-05-000973
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>








Mail Stop 6010


      August 4, 2005



Mr. David Seligman
Chief Financial Officer
NUR Macroprinters LTD.
12 Abba Hillel Silver Street
P.O. Box 1281
Lod 71111, Israel

      RE: 	NUR Macroprinters LTD
		Form 20-F for the fiscal year ended December 31, 2004
		File No. 000-26498

Dear Mr. Seligman,

      We have reviewed your filings and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  Where indicated, we think you should
revise your documents in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


Form 20-F for the year ended December 31, 2004

Item 5 - Operating and Financial Review and Prospects, page 31

Year ended December 31, 2004 compared with Year ended December 31,
2003, page 39

1. We note the bad debt write-offs of $6.3 and $6.7 million you
recorded for the years ended December 31, 2004 and 2003,
respectively.  Please revise future filings to include a
discussion
of the circumstances surrounding the material bad debt write-offs
recorded during the periods.

2. In addition, in future filings, please revise your allowance
for
doubtful accounts critical accounting estimate discussion on page
35
to describe the risks inherent in your trade receivable portfolio
which resulted in an allowance of more than 50% of the gross
outstanding balance at December 31, 2004.

Item 15 - Controls and Procedures, page 97

3. We note your disclosure that your "disclosure controls were
effective as of such date to ensure that information required to
be
disclosed in NUR`s reports filed under the Securities Exchange Act
of
1934 is recorded, processed, summarized and reported within the
time
periods specified in Securities and Exchange Commission rules and
forms."   Please revise future filings to clarify, if true, that
your
officers concluded that your disclosure controls and procedures
are
also effective to ensure that information required to be disclosed
in
the reports that you file or submit under the Exchange Act is
accumulated and communicated to your management, including your
chief
executive officer and chief financial officer, to allow timely
decisions regarding required disclosure.  See Exchange Act Rule
13a-
15(e).

Consolidated Financial Statements, page F-2

4. We note that Kost Forer Gabbay and Kasierer`s opinion as it
relates to certain consolidated subsidiaries is based solely on
the
report of another auditor.  Since your auditors, Kost Forer Gabbay
and Kasierer, have referred to another accountant`s report in
their
opinion, please amend the filing to include the audit report of
the
other auditors.  Refer to Rule 2-05 of Regulation S-X.

Consolidated Statements of Operations, page F-5

5. We note from your disclosure on page 38 that service and other
revenues approximated 11%, 14% and 15% of your total revenues for
the
years ended 2002, 2003 and 2004, respectively.  In future filings,
please revise this statement to separately present revenues from
services as well as the related costs of service revenues on its
face. See Rule 5-03(b) of Regulation S-X.

Note 2 - Significant Accounting Policies, page F-15

F - Inventories, page F-16

6. We note from the statements of cash flows that you transferred
property, plant and equipment to inventory during 2003 and 2004.
Please tell us the nature of these costs, how you account for them
and explain why classification as inventory is appropriate.

Note 11- Long Term Loans

C - Convertible Loan Agreement, page F-31

7. To help us better understand your accounting for the July 2003
Loan and Warrant transactions with certain existing shareholders,
please provide us with sample journal entries showing how you
accounted for the debt at issuance, including the warrants granted
to
the placement agent and the beneficial conversion feature.
Clearly
explain how you determined the value of the warrants and the
beneficial conversion feature.

Note 13 - Commitments and Contingencies, page F-35

B - Royalty Commitments, page F-35

8. We note that you are required to repay the OCS, Government of
Belgium and the Fund for the Encouragement of Marketing Activity
for
past grants received based on sales derived from products
developed
with those grants.  Please revise your future filings to disclose
your maximum potential liability under these agreements.

9. Your disclosure in this note that you have no contingent
obligation to pay royalties to the OCS and the Government of
Belgium
appears to contradict the disclosure on page 27 that you have a
contingent liability of $800,000 for future royalties to the OCS.
Please tell us how your contingent liabilities are calculated and
how
you account for these liabilities.  Please revise future filings
to
remove this inconsistency or advise us.

D - Litigations, page F-36

10. We note your discussion of litigation with Screen + in your
legal
proceedings but we note no additional discussion in the notes to
the
financial statement.  Please tell us and revise future filings to
indicate the damages sought by the plaintiff and the range of
possible loss.  Refer to paragraph 10 of SFAS 5.

	As appropriate, please amend your December 31, 2004 Form 20-F
and respond to these comments within 10 business days or tell us
when
you will provide us with a response.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information. Please file your
cover letter on EDGAR.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.


      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Eric Atallah, Staff Accountant at (202) 551-
3663
or me at (202) 551-3671 regarding comments on the financial
statements and related matters.

      							    Sincerely,


							    Martin F. James
		                   				    Senior Assistant
Chief Accountant
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Mr. David Seligman
NUR Macroprinters, LTD
August 4, 2005
Page 5






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