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 March 21, 2025

Adel Al-Saleh
Chief Executive Officer
SES S.A.
Ch teau de Betzdorf
L-6815 Betzdorf
Grand Duchy of Luxembourg

 Re: SES S.A.
 Correspondence Submitted March 7, 2025
 Amendment No. 1 to Draft Registration Statement on Form S-4
 CIK No. 0001347408
Dear Adel Al-Saleh:

 We have reviewed your correspondence and have the following comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 1 to Draft Registration Statement on Form F-4
Presentation of Financial and Other Information, page 2

1. In your response to prior comment one of our letter dated December 5,
2024, you
 identify a number of factors as to why you lack sufficient information
to determine a
 reasonable fair value of the CVRs to present in the pro forma financial
information.
 You further indicate that once the acquisition has closed, you intend to
engage a
 valuation specialist to perform purchase price allocation for purposes
of business
 combination accounting and to assist in the assessment of the fair value
of the CVRs.
 However, the factors you identify appear to relate to uncertainties that
would still be
 present once the acquisition has closed, rather than specific
information that you need
 to estimate the fair value, incorporating these uncertainties. Please
further clarify how
 March 21, 2025
Page 2

 you considered including a provisional amount for this liability in a
future amendment
 as of the most recent practicable date prior to the effectiveness of
your registration
 statement or presenting a range of possible outcomes. Clarify the
specific information
 that you do not have with respect to facts and circumstances that exist
as of this date
 preventing you from estimating a provisional amount. Also, tell us how
you
 considered information used in the negotiations of the terms of this
transaction in
 determining a provisional amount or a range of possible outcomes. In
this regard, your
 disclosures should include information that will enable readers to
understand the
 magnitude of the liability. Refer to Article 11-02(a)(10) and(11)(ii)(A)
and (B) of
 Regulation S-X.
2. Clarify how you will evaluate whether the factors used by the valuation
specialist to
 determine the fair value of the CVRs after the acquisition has closed
reflect
 information about facts and circumstances that existed as of the
acquisition date rather
 than results from events that occurred after the acquisition date. In
this regard, your
 response appears to refer to activities and events that will take place
after the
 acquisition has closed that you will use to determine the fair value.
Refer to
 paragraphs 45 and 47 and IFRS 3.
3. We will review your pro forma information and disclosures, once included
in a future
 amendment with your updated financial statements for the year ended
December 31,
 2024, and may have additional comments with respect to the CVRs.
 Please contact Laura Veator at 202-551-3716 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters.
Please contact Matthew Crispino at 202-551-3456 or Larry Spirgel at
202-551-3815 with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
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