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                            August 15, 2022

       Yael Shofar
       General Counsel
       Gilat Satellite Networks LTD
       Gilat House
       21 Yegia Kapayim Street
       Kiryat Arye, Petah Tikva, 4913020 Israel

                                                        Re: Gilat Satellite
Networks LTD
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2021 filed May 16, 2022
                                                            Form 6-K Filed
August 9, 2022
                                                            File No. 000-21218

       Dear Mr. Shofar:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

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

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

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

       Item 15: Controls and Procedures
       Disclosure Controls and Procedures, page 111

   1.                                                   We note your
conclusions that disclosure controls and procedures were effective but that
                                                        internal controls over
financial reporting were not effective as of December 31, 2021.
                                                        Please tell us how
management was able to conclude that disclosure controls and
                                                        procedures were
effective given the substantial overlap with internal controls over
                                                        financial reporting.
Refer to SEC Release No. 33-8238. Your response should also address
                                                        how the material
weaknesses you identified in internal controls over financial reporting
                                                        did not impact your
disclosure controls and procedures. Alternatively, please revise your
                                                        Form 20-F to present
consistent conclusions for both disclosure controls and procedures
                                                        and internal controls
over financial reporting.
 Yael Shofar
FirstName   LastNameYael  Shofar
Gilat Satellite Networks LTD
Comapany
August  15, NameGilat
            2022       Satellite Networks LTD
August
Page  2 15, 2022 Page 2
FirstName LastName
Item 18: Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2

2.       We note the second sentence of the first paragraph of the auditors'
report states that    in
         our opinion, the consolidated financial statements present fairly, in
all material respects,
         the financial position of the Company at December 31, 2021 and 2020,
and the results of
         its operations and its cash flows for each of the three years in the
period ended December
         31, 2020   . Please revise your Form 20-F to include an audit report
from your registered
         public accounting firm that opines on the audited financial statements
for the three years
         in the period ended December 31, 2021.
Notes to Consolidated Financial Statements
Note 2: Significant Accounting Policies
l. Revenue recognition, page F-23

3.       We note the following disclosures related to when and how you
recognize revenue:
             revenue from long term contracts is recognized over time because
of continuous
              transfer of control to the customer using the cost to cost
measure of progress;
             revenue from the sale of equipment is recognized at a point in
time when the
              customer obtains control or when acceptance occurs;
             products revenue includes construction of networks; and
             revenue from periodic services are recognized ratably over the
term services are
              provided.
         Please tell us what consideration you have given to providing
disaggregated revenue
         disclosures based on contract type and/or the timing of the transfer
of products and
         services since it appears those factors would impact how economic
factors affect the
         nature, amount, timing, and uncertainty of revenue and cash flows.
Refer to ASC 606-10-
         55-90 and 91. We also note your auditors' report includes a CAM
related to revenue from
         long term contracts; however, it is not clear how much of your revenue
relates to such
         contracts.
Note 15: Customers, Geographic and Segment Information, page F-58

4.       In future filings, please separately disclose revenue by individual
country, including
         revenue related to the US and/or Canada, to the extent material, as
required by ASC 280-
         10-50-41.
Form 6-K Filed August 9, 2022

Reconciliation Between GAAP and Non-GAAP Consolidated Statements of Income
(Loss), page
8

5.       We note that the individual adjustments to non-GAAP gross profit and
non-GAAP
         operating expenses for the three-month and six-month periods ended
June 30, 2022 do not
         appear to reconcile to the adjustment totals presented in the summary
tables. Please
 Yael Shofar
Gilat Satellite Networks LTD
August 15, 2022
Page 3
         provide us explanations for the differences and revise future filings
as appropriate. In
         addition, please explain to us if/how you determine the tax effects of
non-GAAP
         adjustments to Non-GAAP net income as required by Question 102.11 of
the C&DIs
         related to Non-GAAP Financial Measures.
       In closing, 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
with any questions.



FirstName LastNameYael Shofar                                   Sincerely,
Comapany NameGilat Satellite Networks LTD
                                                                Division of
Corporation Finance
August 15, 2022 Page 3                                          Office of
Manufacturing
FirstName LastName