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                                                            March 31, 2020

Eli Kalif
Chief Financial Officer
Teva Pharmaceutical Industries Limited
5 Basel Street
Petach Tikva, ISRAEL, 4951033

       Re: Teva Pharmaceutical Industries Limited
           Form 10-K for the Fiscal Year Ended December 31, 2019
           Filed February 21, 2020
           File No. 001-16174

Dear Mr. Kalif:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to the comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to the comment, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2019

Consolidated Financial Statements
Note 11 - Legal settlements and loss contingencies, page 145

1.    During 2019, you recorded an expense of $1,178 million in legal
settlement and loss
      contingencies "mainly related to an estimated settlement provision
recorded in connection
      with the remaining opioid cases," of which $646 million was recorded in
the second
      quarter and $468 million was recorded in the third quarter. Please
describefor us the
      methods and key assumptions used to calculate these loss provisions,
particularly the
      factors that you considered in distinguishing between opioid cases deemed
to be probable
      or not probable. In addition, provide us the following information in
your response.

           For the $646 million loss provision, quantify the specific amounts
associated with the
           Oklahoma litigation, as well as the general loss provision for "a
portion of opioid-
           related cases as probable" based on this settlement.
 Eli Kalif
Teva Pharmaceutical Industries Limited
March 31, 2020
Page 2
              For the $468 million loss provision, quantify the specific
amounts associated with the
              settlement with "two plaintiffs in the MDL Opioid Proceeding" and
the agreement in
              principle with North Carolina, Pennsylvania, Tennessee and Texas,
as well as the
              general loss provision for "more likely" opioid-related cases
based on these
              settlements.
              Explain the factors considered in determining the timing for
recognition of these two
              opioid loss provisions.
              Quantify for us your range reasonably possible losses related to
your opioid exposure,
              and explain why you did not disclose such range pursuant to ASC
450-20-50-4.
              Explain the terms, obligations and rights associated with the
nationwide settlement
              framework and how you expect this arrangement to operate in
future periods,
              particularly the expected timing for recognition of costs
associated with your
              provision of up to $23 billion of sublingual tablets and up to
$250 million of cash
              payments over a ten-year period.
              Describe your expected accounting treatment for each element of
this nationwide
              settlement framework. Refer us to the applicable authoritative
accounting guidance.


       In closing, 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.

       You may contact Ibolya Ignat at (202) 551-3636 or Franklin Wyman at
(202) 551-3660
with any questions.



FirstName LastNameEli Kalif                                   Sincerely,
Comapany NameTeva Pharmaceutical Industries Limited
                                                              Division of
Corporation Finance
March 31, 2020 Page 2                                         Office of Life
Sciences
FirstName LastName
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