SecProbe.io

September 2 4, 2012
Via E -mail
Mr. Yaniv Reinhold
Chief Financial  Officer
Gilat Satellite Networks L td.
Gilat House
21 Yegia Kapayim Street
Kiryat Arye, Petah Tikva
49130   Israel

Re: Gilat Satellite Networks Ltd.
Form 20-F for the Fis cal Year Ended December 31, 2011 , as Amended
Filed  April 2, 2012
 File No. 000-21218

Dear Mr.  Reinhold:

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 .  In our comment, we
asked that  you to provide us with information so we may better understand your disclosure.
Please comply with this comment in future filings.  Confirm in writi ng that you will do so and
explain to us how you intend to comply.

Please respond to this letter within ten business days by providing the requested
information or by advising us when you will provide the requested response.   If you do not
believe our c omment  applies  to your facts and circumstances, please tell us why in your
response.

After reviewing the information you provide in response to th is comment, we may have
additional comments.

Our business focus on defense and related defense markets… page 13
A decline or reprioritization of funding in the US defense budget… page 14
We are dependent on contracts with governments … page 13

1. We note that a significant amount of your revenue is derived from government contracts,
particularly contracts with  the Departments of Defense and Homeland Security.  In a note
to the financial statements, please disclose your accounting policies for government
contracts and provide the related disclosures, and advise us.  Refer to ASC 912 -235-50-1.

Mr. Yaniv Reinhold
Gilat Satellite Networks L td
September 2 4, 2012
Page 2

 Please file all correspondence over EDGAR.  We urge all persons who are responsible
for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes
the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules
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 responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not forec lose
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.

You may contact Kathryn Jacobson, S enior  Accountant, at (202) 551 -3365 or Robert S.
Littlepage, Accountant Branch Chief , at (202) 551 -3361  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/ Robert S. Littlepage  for

        Larry Spirgel
        Assistant Director