United States securities and exchange commission logo

                            June 23, 2022

       Eyal Rubin
       Senior Vice President and Chief Financial Officer
       Protalix BioTherapeutics, Inc.
       2 University Plaza, Suite 100
       Hackensack, NJ 07601

                                                        Re: Protalix
BioTherapeutics, Inc.
                                                            Form 10-K for the
Year Ended December 31, 2021
                                                            Filed March 31,
                                                            File No. 001-33357

       Dear Mr. Rubin:

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

              Please respond to these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 10-K for the Year Ended December 31, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page

   1.                                                   You disclose on page 64
that you currently do not record and maintain research and
                                                        development costs per
project. You also disclose on page 66 that the decrease in your
                                                        research and
development expense was primarily due to the completion of the three phase
                                                        III clinical trials of
PRX-102. Please revise your future filings to provide a quantified
                                                        breakdown of research
and development costs by nature of expense for each period
                                                        presented. As part of
your breakdown, separately identify the amount of cost
                                                        reimbursement netted
against such expenses. Please provide us with an example of your
                                                        proposed disclosure in
your response.

              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
 Eyal Rubin
Protalix BioTherapeutics, Inc.
June 23, 2022
Page 2

absence of action by the staff.

      You may contact Tracie Mariner, Staff Accountant, at (202) 551-3744 or
Kevin Vaughn,
Branch Chief, at (202) 551-3494 with any questions.

FirstName LastNameEyal Rubin                            Sincerely,
Comapany NameProtalix BioTherapeutics, Inc.
                                                        Division of Corporation
June 23, 2022 Page 2                                    Office of Life Sciences
FirstName LastName