SecProbe.io

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Mail Stop 0407

      							July 28, 2005

Mr. Raya Asher
Chief Financial Officer
Magal Security Systems Ltd.
PO Box 70
Industrial Zone, Yehud 56100
Israel

	Re:	Magal Security Systems Ltd.
      Form 20-F for Fiscal Year Ended December 31, 2004
		Filed June 30, 2005

		File No. 0-21388

Dear Mr. Asher:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Please address the following comments
in
future filings.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a future 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 or may not 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 filing.
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 Fiscal Year Ended December 31, 2004

Consolidated Statements of Income, page F-5

1. State separately your revenues and costs of revenue by goods
and
services. Refer to Rule 5-03 of Regulation S-X.

	Note 2: Significant Accounting Policies
	Impairment of long-lived assets, page F-14

2. Tell us how you concluded no impairment losses were identified
for
your long-lived assets.  Specifically, we note that you have $5.8
million in long-lived assets related to your video-monitoring
segment, and this segment has incurred increasing operating losses
for the last three years.

Revenue recognition, page F-15

3. We note that you are using "input method" to recognize revenue
from the installation of comprehensive security systems under the
percentage of completion method.  Tell us why you believe the
input
measure is a better measure of performance than the contract
milestones, an output measure, which is more reliable than the
input
measure.

4.  Disclose if title and risk of loss transfers to your customer
upon their acceptance of each milestone under your contracts.
Also,
please disclose more detail about the origin of your unbilled
accounts receivable.  Specifically, disclose why you are
recognizing
revenue prior to billing for each milestone under the contract and
the approximate time frame that elapses between an unbilled
accounts
receivable and a billed accounts receivable.

Note 9: Commitments and Contingent Liabilities
Guarantees, page F-27

5. Please revise to comply with the disclosure requirements of FIN
45.

* * * * *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detail letters greatly facilitate our
review.
Please file your response letter via 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 to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 filings; 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 filings or
in
response to our comments on your filings.

      You may contact Bob Carroll, Staff Accountant, at (202) 551-
3362 or Ivette Leon, Assistant Chief Accountant, at (202) 551-3351
if
you have questions regarding comments on the financial statements
and
related matters.  Please contact me at (202) 551-3810 with any
other
questions.

								Sincerely,

								 /s/ Kyle Moffatt for

								Larry Spirgel
								Assistant Director
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Mr. Rava Asher
Magal Security Systems, Ltd.
July 28, 2005
Page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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