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      Confidential Treatment Requested by Elbit Systems Ltd.*

      Elbit Systems Ltd. – PAGE E004

    April 4, 2023

    VIA EDGAR AND ELECTRONIC DELIVERY

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Manufacturing

    100 F Street, N.E.

    Washington, DC 20549 USA

    Attention:          Claire Erlanger

                               Kevin Woody

    Re:          ELBIT
          SYSTEMS LTD (the “Company”)

    Form 20-F for the Year Ended December 31, 2021 (the “2021 20-F”)

    Response Letter Dated March 20, 2023

    File No. 000-28998

    Dear Ms. Erlanger and Mr. Woody:

    We set forth herein our responses to the comments contained in the letter of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange
      Commission (the “Commission”) dated March 23, 2023, with respect to our response letter referenced above. For your convenience, prior to our response below, we restated the applicable Staff comment.

    Form 20-F for the Year Ended December 31, 2021

    Note 23. Major Customers and Geographic Information, page F-73

    Comment:

          1.

            We note from your response that you intend to modify your segment disclosure to transition from one reportable segment to five reportable segments starting with the Form 20-F for the year
              ended December 31, 2022.  Please explain to us whether you determined the change in the number of segments was due to an error in your identification of operating segments and if so, please tell us how you evaluated the materiality of the
              error on your financial statements and related disclosures and the impact on your conclusions regarding the effectiveness of internal controls over financial reporting and disclosure controls and procedures. If you do not believe this was an
              error, please explain why. In this regard, it appears from your response that the change was due to evaluating judgements regarding the application of ASC 280 during the year end process, rather than a change in your business or to
              information used by the CODM to allocate resources or assess performance. Please explain.

    * Due to the commercially sensitive nature of information contained in this letter, this submission is accompanied by the Company’s request for confidential treatment for
      selected portions of this letter, which have been replaced with the following placeholder “[***]” in the letter filed via EDGAR. The Company has filed a separate letter with the Office of Freedom of Information and Privacy Act Operations in
      connection with the confidential treatment request pursuant to Rule 83 of the Commission’s Rules on Information and Requests (17 C.F.R. § 200.83). The Company has also delivered a complete unredacted copy of the letter to its examiner at the Division
      of Corporation Finance.

      Elbit Systems Ltd. Advanced Technology Center, P.O.B 539, Haifa 3100401, Israel

      Confidential Treatment Requested by Elbit Systems Ltd.*

      Elbit Systems Ltd. – PAGE E005

    Response:

    The Company does not believe its decision to transition from one reportable segment to five reportable segments was due to an error in the identification of its segments.
      Rather, the determination reflects a shift in judgment in connection with the Company’s financial statement closing process for the fiscal year ended December 31, 2022 and in light of the Staff’s comments.  The Company believes the decision reflects
      the complexity of ASC 280 and the judgment required to apply it.

    As detailed in the Company’s prior responses to the Staff’s comments dated December 12, 2022, January 19, 2023 and March 20, 2023, the Company believes its historical approach
      of one reportable segment was justified under ASC 280.  The substantial size of intersegment eliminations in the draft segment disclosure ([***]), as presented in the Company’s March 20, 2023 letter, also underscores the extensive collaboration among
      the Company’s business units (“BUs”), and room for differing good-faith views when applying ASC 280 to the Company.

    However, as described in the Company’s letter dated March 20, 2023, the Company has determined that transitioning to five reportable segments is a better approach under ASC 280
      and also has the benefit of providing investors with additional useful disaggregated information.  In addition, the Company’s determination was influenced by its financial performance for the fiscal year ended December 31, 2022, which resulted in a
      decision by the CODM, and corresponding notifications to the general managers (“GMs”) of each BU, to significantly increase its focus on each BU’s execution.  Beginning in 2023, the CODM requires each BU’s GM to frequently report its performance on
      an additional set of financial and operational matrices, in order to more closely monitor each BU’s performance and the corresponding invested resources utilized by each BU.

    In view of the Company’s goal of resolving the Staff’s comments in advance of filing the Company’s Form 20-F for the fiscal year ended December 31, 2022, and in appreciation of
      the Staff’s comments, the Company also evaluated, for the avoidance of any doubt, whether a change in its reportable segments would have materially affected its historical financial statements based on SAB Topic 1.M or its previous conclusions that
      the Company had effective internal control over financial reporting and effective disclosure controls and procedures.  As detailed in Annex A, the Company concluded that any such change would not have materially affected its historical
      financial statements or its conclusions about the effectiveness of its internal control over financial reporting and disclosure controls and procedures.

    Comment:

    2.  We note from your response that you intend to modify the notes to the financial statements to provide information related to the
      newly identified segments. Please review the guidance in ASC 280-10-50 and ensure your revised disclosure provides all information required by this guidance.

    Response:

    The Company has reviewed the guidance in ASC 280-10-50 to ensure its revised disclosure in Annex B provides all relevant information required by this guidance and will
      recast its segment disclosures on a retrospective basis, providing the revised proposed financial statement note disclosures for the three years ended December 31, 2022, as shown in Annex B.

    If you have any questions or comments regarding these responses or require any additional information, please do not hesitate to contact me at:
      kobi.kagan@elbitsystems.com.

      Elbit Systems Ltd. Advanced Technology Center, P.O.B 539, Haifa 3100401, Israel

      Confidential Treatment Requested by Elbit Systems Ltd.*

      Elbit Systems Ltd. – PAGE E006

                Very truly yours,

                ELBIT SYSTEMS LTD.

                By:      /s/ Kobi Kagan

                Name: Dr. Kobi Kagan

                Title:   Executive Vice President and Chief Financial Officer

              cc:

                Jonathan Ariel, Adv., Executive Vice President and Chief Legal Officer, Elbit Systems Ltd.

              Adam Fleisher, Esq., Cleary Gottlieb Steen & Hamilton LLP

              Joshua Ravitz, Adv., Herzog Fox & Neeman

      Elbit Systems Ltd. Advanced Technology Center, P.O.B 539, Haifa 3100401, Israel

      Confidential Treatment Requested by Elbit Systems Ltd.*

      Elbit Systems Ltd. – PAGE E007

    Annex A:  Materiality Analysis

    Per SAB Topic 1.M, Assessing materiality, “A matter is ‘material’ if there is a substantial
        likelihood that a reasonable person would consider it important.”  As for qualitative characteristics, the FASB stated the essence of the concept of materiality as follows:  “The omission or misstatement of
        an item in a financial report is material if, in the light of surrounding circumstances, the magnitude of the item is such that it is probable that the judgment of a reasonable person relying upon the report would have been changed or influenced by
        the inclusion or correction of the item.”

    As outlined in the Company’s letter dated March 20, 2023, the Company historically identified each of its BUs as reporting units for goodwill impairment testing and has not
      experienced any goodwill impairment.  Because the Company’s determination of its reportable segments aligns with its historical BUs, the Company did not have to perform retrospective impairment tests, and there is no risk of any potential impairment
      loss in connection with the change to five reporting segments.  As a result, even if an error had occurred, it would have had no quantitative effect.

    In addition to analyzing the quantitative impact of the change in reportable segments, the Company also evaluated, on a qualitative basis, whether the omission of segment
      disclosure in prior years could be considered a material error, in accordance with the guidance provided by SAB Topic 1.M.  Although the Company historically reported one reportable segment, the Company for years consistently disclosed the following
      in accordance with ASC 280:

    a.  Areas of operations – The area of operations disclosure provided users of the financial statements with a breakdown and insights into the Company’s
      consolidated revenue from different types of operations.

    b.  Geographical areas – The Company also disclosed geographical splits, which provided a view of the diversity of locations where the Company’s customers
      are, and enabled users of the financial statements to assess the Company’s exposure to different locations.

    Although the information disclosed regarding the Company’s areas of operations and geographical breakdown was not as detailed as what would have been required if the Company
      had previously identified reportable segments, the Company believes that it provided relevant and useful information to enable users to assess its performance.

    The Company does not believe that a reasonable person would consider the information that would have been disclosed had the Company reported in separate segments necessary to
      make investment decisions about the Company.

    Additionally, the Company has considered the following qualitative factors noted in SAB Topic 1.M.:

          •

            Whether the misstatement arises from an item capable of precise measurement or whether it arises from an estimate and, if so, the degree of imprecision inherent in the estimate

    The change in reportable segments does not result in any changes to any reported financial results.  Segment analysis is a process that requires significant
      judgment and does not involve precise or estimated measurements.

          •

            Whether the misstatement masks a change in earnings or other trends

    The change in reportable segments does not reveal any previously undisclosed material results or trends.

        Elbit Systems Ltd. Advanced Technology Center, P.O.B 539, Haifa 3100401, Israel

      Confidential Treatment Requested by Elbit Systems Ltd.*

      Elbit Systems Ltd. – PAGE E008

    The vast majority of the Company’s revenues for the reported periods were derived from defense, security and homeland security end-markets.  The long-term
      trends in these end-markets and their impact on long-term revenue growth and profitability are generally similar across the Company’s segments.

    The 2021 20-F disclosed the factors that drove major year-over-year changes in revenue and income at the segment level:

          o

            The disclosure explains that the significant increase in Aerospace activities revenues from 2020 to 2021 resulted from airborne precision-guided munition sales, following a significant contract win in Asia-Pacific.  (“The increase in
              revenues in the area of airborne systems was mainly a result of sales of airborne precision guided munitions in Asia-Pacific.”)

          o

            Similarly, the disclosure describes the negative effect of COVID-19 in 2020 on the Company’s commercial aviation activities (part of the Aerospace segment). (“Over the last two years the Covid-19 pandemic has impacted global supply chains
              and caused temporary disruptions to the commercial avionics market. This resulted in our incurring approximately $60 million in non-cash expenses in the third quarter of 2020 relating to our commercial aviation activities.”)  The
              precision-guided munition sales, together with this write-off, in turn were the primary drivers for Aerospace segment revenues and income in 2021.

          o

            In addition, the disclosure explains that the increase in revenue in North America (mainly the ESA segment) was principally the result of including three quarters of sales from Sparton, which was acquired in 2021, as well as growth in
              sales of medical instrumentation.  (“The increase in North America in 2021 was mainly a result of higher sales of airborne systems and Sparton’s products, as well as growth in sales of medical instrumentation.”)  These sales similarly were
              the principal driver for the increase in ESA segment income in 2021.

          •

            Whether the misstatement hides a failure to meet analysts’ consensus expectations for the enterprise

    The change in reportable segments does not hide a failure to meet analysts’ consensus expectations for the Company.  The Company does not provide guidance
      for future revenues and profit.  However, the Company believes the disaggregation of revenues by area of operations and geographical areas, along with additional information provided in the Company’s annual report on Form 20-F and current reports on
      Form 6-K, particularly the Company’s MD&A disclosure, has enabled analysts to assess trends within the business as it has evolved over time, and provided equity and debt investors with sufficient information to make their investment decisions:

          o

            Defense companies like Elbit generally operate in a similar legal and regulatory environment, under similar customer budgetary constraints and through similar distribution channels.

          o

            Given these broad industry conditions, as well as the substantial joint collaboration among the Company’s segments, as noted above, the Company believes that investors and analysts primarily focus on the Company’s consolidated results and
              the historically disclosed disaggregation of revenues by area of operation and geography, together with the Company’s other disclosure.

          o

            Investors and analysts are familiar with the acceptable margins for defense companies that operate in a heavily regulated industry with a relatively small number of end-customers and suppliers.  The Company’s experience – including, for
              example, with analyst questions on the Company’s quarterly earnings calls – is that they focus on consolidated growth and profitability, and that geographic mix and operational execution drive their expectations more than a particular product
              line or segment.

        Elbit Systems Ltd. Advanced Technology Center, P.O.B 539, Haifa 3100401, Israel

      Confidential Treatment Requested by Elbit Systems Ltd.*

      Elbit Systems Ltd. – PAGE E009

          •

            Whether the misstatement changes a loss into income or vice versa

    The change in reportable segments does not impact the consolidated results of the Company.

          •

            Whether the misstatement concerns a segment or other portion of the registrant’s business that has been identified as