SecProbe.io

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Mail Stop 0407

      April 21, 2005

Daniel S. Goldberg
President
New Skies Satellites Holdings Ltd.
c/o CT Corporation System
111 Eighth Avenue
New York, NY  10011

	RE:  	New Skies Satellites Holdings Ltd.
      Registration Statement on Form S-1/A
      Draft Received on April 14, 2005
      File No. 333-122322

Dear Mr. Goldberg:

      We have reviewed the draft amendment to your Form S-1 and
have
the following comments.  Where indicated, we think you should
revise
your document in response to these comments.  If you disagree, we
will consider your explanation as to why our comment is
inapplicable
or a 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 supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

General
1. We note your Chief Executive Officer`s April 13, 2005 testimony
before a House subcommittee in which he advocated changes to the
ORBIT Act provisions that prohibit a merger of New Skies and
Intelsat
before 2012.  Tell us in your response letter what consideration
you
have given to revising your disclosure to reflect your desire to
pursue acquisitions, strategic combinations or other strategic
transactions with Intelsat and other satellite communications
companies as a means to address competition in your industry.  In
this regard, please address whether this desire is consistent with
your dividend policy, which limits your ability to pursue growth,
including significant acquisitions, during the initial four
quarters.
Dividend Policy and Restrictions, page 39

	Estimated Cash Available to Pay Dividends..., page 41
2. We note your response to comment 4.  Please clarify for us why
you
cannot estimate the amount annually since you believe you will
generate enough Adjusted EBITDA to pay dividends on a quarterly
basis.  If you continue to believe that you are unable to
calculate
the amount based on minimum Adjusted EBITDA for each quarter,
revise
your table to include reference to this covenant and if true,
include
a statement confirming that you believe you would meet the
requirements of this covenant, as  indicated on page 51, for each
of
the Initial Four Quarters.

      Stock Compensation, page 84
3. We note that you refer to an independent valuation for your
calculation of non-cash stock-based compensation expense.  While
you
are not required to make reference to this independent valuation,
when you do, you should include the consent of the expert in your
Form S-1.  Your disclosures should explain the method that
management
used to determine the valuation.  Please revise to comply.

Exhibits
4. Please note in the index that you are seeking confidential
treatment concerning portions of exhibits 10.34 and 10.35.

      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.

*	*	*	*

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with a
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.

	You may contact Kathleen Kerrigan, Staff Accountant, at (202)
942-1944, or Robert Littlepage, Accountant Branch Chief, at (202)
942-1947, if you have any questions regarding comments on the
financial statements and related matters.  Please contact Cheryl
Grant, Staff Attorney, at (202) 942-1916, or me, at (202) 942-
1990,
with any other questions.  Beginning Monday, April 25, 2005, you
may
reach each of us at (202) 551-3810, instead of at the previous
telephone numbers.

					Sincerely,

					Larry Spirgel
					Assistant Director

cc:	via facsimile (212) 455-2502
      Rise Norman, Esq.
	Simpson, Thatcher & Bartlett LLP

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Mr. Goldberg
New Skies Satellites Holdings Ltd.
April 21, 2005
Page 3

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