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                              June 16, 2020

       Ophir Yakovian
       Chief Financial Officer
       Caesarstone Ltd.
       Kibbutz Sdot-Yam
       MP Menashe, 3780400
       Israel

                                                        Re: Caesarstone Ltd.
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2019
                                                            Filed March 23,
2020
                                                            Form 6-K filed May
6, 2020
                                                            File No. 001-35464

       Dear Mr. Yakovian:

             We have reviewed your filing and have the following comment. In
our comment, we
       may ask you to provide us with information so we may better understand
your disclosure.

              Please respond to this comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this comment, we may have additional comments.

       Form 6-K filed on May 6, 2020

       Exhibit 99.1, page 1

   1.                                                   We note your disclosure
that "Beginning with first quarter 2020 results, the Company has
                                                        modified its
presentation of regional revenue reporting to align with the Company's new
                                                        organizational
structure, and strategic initiatives across its global footprint" and you have
                                                        four geographic regions
that comprise the Americas, Asia/Pacific (APAC), Europe/Middle
                                                        East/Africa (EMEA) and
Israel. Please address the following:
                                                          Explain your new
organizational structure, including the roles of regional managing
                                                            directors;
                                                          Tell us how you
assessed whether each geographic region is an operating segment as
                                                            defined in ASC
280-10-50-1. If you have determined that your geographic regions
                                                            are operating
segments that can be aggregated, demonstrate how you determined that
                                                            aggregation
complies with the requirements of ASC 280-10-50-11, including similar
 Ophir Yakovian
Caesarstone Ltd.
June 16, 2020
Page 2
              economic characteristics. If you have determined that your
geographic regions are
              not operating segments, explain how you made that determination;
              Identify your CODM and explain how that determination was made;
and
              Describe the nature and extent of the financial information
reviewed by your CODM
              to assess performance and allocate resources, including
specifically addressing the
              nature and extent of financial information available by
geographic region.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Dale Welcome at 202-551-3865 or Anne McConnell at
202-551-3709 if
you have any questions.



FirstName LastNameOphir Yakovian                             Sincerely,
Comapany NameCaesarstone Ltd.
                                                             Division of
Corporation Finance
June 16, 2020 Page 2                                         Office of
Manufacturing
FirstName LastName