SecProbe.io

October 24, 2014

Via E -mail
Erez Antebi
Chief Executive Officer
Gilat Satellite Networks Ltd.
Gilat House
21 Yegia Kapayim Street
Kiryat Arye
Petah Tikva, 49130 Israel

 Re: Gilat Satellite  Networks Ltd.
Form 20-F for Fiscal Year E nded December 31, 20 13
Filed March 31, 2014
Form 000 -21218

Dear Mr. Antebi :

We have reviewed your filing s and have the following comments.  Please comply with
the following comments in future filings.  Confirm in writing that you will do so and explain to
us how you intend to comply.   In some of our comments, we may ask you to provide us with
information so w e may better understand your disclosure.

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

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

Item 5: Operating and Financial Review and Prospects, page 40

Year Ended December 31, 2 013 Compared to Year Ended December 31, 2012 , page 47

1. To provide greater context, please expand your narrative discussion on pages 47 and 48.
We note several competitive trends impacting the network communications industry
under your risk factor and over view sections.  However, please supplement your financial
disclosure with m ore in -depth analysis of events and developments affecting your
operations.  By way of example, include more robust disclosure of the factors driving
decreased commercial sales and the nature of “certain international transactions” that
yield higher margins in your defense segment.

Erez Antebi
Gilat Satellite Networks Ltd.
October 24, 2014
Page 2

 Revenues, page 47

2. Per your disclosure, the revenue decline in the Commercial Division was caused by a
“revenue decrease in Latin America which was attri butable to a delay in two projects,
which revenues were shifted in 2014.”   Notwithstanding, you reported on page 60 that
you received significant advance payments from customers, mainly in Latin
America.   Please tell us the reasons for the delay (i.e., fun ding, performance, etc.) and
why you received significant advance payments despite the project delay.   Further tell us
the nature of these contracts which require significant advance payments and your basis
for the timing and measurement of related revenue s.

Gross profit, page 48

3. In the Defense Division, please tell us the nature of certain high margin international
transactions, which caused its gross profit margin to increase, despite the revenue
slowdown caused by the US DOD sequestration and government shutdown.

Consolidated Statements of Cash Flows, page F -8

4. Please revise your presentation to reconcile (consolidated) net loss to net cash provided
by operating activities.   Refer to ASC 230 -10-45-28.

Note 2: – Significant Accounting Policie s

n. Revenue recognition, page F -21

5. We note your disclosure on page 9 concerning contracts with governments around the
world for a significant portion of your revenues.   We also note your recent awards, such
as the $30 million contract from the Peruvia n government for network construction,
operation, and related services for 10 years.   You also disclosed that as of December 31,
2013, you had a backlog of $228 million for equipment sales and revenues from multi -
year service contracts.   It does not appear  that your accounting for these types of
contracts is covered by the policies disclosed hereunder.   Please tell us and disclose your
basis of accounting for multi -year construction contracts.   Refer to your basis in the
accounting literature.

Note 11: - Taxes on Income, page F -52

6. Please tell us why you incurred a significant domestic loss relative to foreign income
during 2013.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the fili ng includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are

Erez Antebi
Gilat Satellite Networks Ltd.
October 24, 2014
Page 3

 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 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.

You may contact Kathryn Jacobson, Senior Staff Accountant, at (202) 551 -3365 , or Dean
Suehiro, Senior Staff Accountant, at (202) 551 -3384  if you have questions regarding comments
on the financial statements and related matters.  Please contact Justin Kisner, Attorney -Adviser,
at (202) 551 -3788  or Celeste M. Murphy, Legal Branch Chief, at (202) 551 -3257, or me at  (202)
551-3810  with any other  questions.

Sincerely,

 /s/ Celeste M. Murphy for

Larry Spirgel
Assistant Director

cc: Via E -mail
Alon Levy
Gilat Satellites Network Ltd.

Steven J. Glusband, Esq.
Carter Ledyard & Milburn LLP