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<SEC-DOCUMENT>0000000000-08-048151.txt : 20081229
<SEC-HEADER>0000000000-08-048151.hdr.sgml : 20081225
<ACCEPTANCE-DATETIME>20080924131915
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-08-048151
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20080924

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			ELBIT SYSTEMS LTD
		CENTRAL INDEX KEY:			0001027664
		STANDARD INDUSTRIAL CLASSIFICATION:	AIRCRAFT PART & AUXILIARY EQUIPMENT, NEC [3728]
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			L3
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		ADVANCED TECHNOLOGY CENTER
		STREET 2:		PO BOX 539
		CITY:			HAIFA, ISRAEL
		STATE:			L3
		ZIP:			31053
		BUSINESS PHONE:		01197248316626

	MAIL ADDRESS:	
		STREET 1:		ADVANCED TECHNOLOGY CENTER
		STREET 2:		PO BOX 539
		CITY:			HAIFA, ISRAEL
		STATE:			L3
		ZIP:			31053
PUBLIC REFERENCE ACCESSION NUMBER:		0000910680-08-000436
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>




Mail Stop 3561
								September 23, 2008

Via Fax & U.S. Mail

Mr. Joseph Gaspar
Chief Financial Officer
Advanced Technology Center
P.O.B. 539
Haifa 31053, Israel

Re:	Elbit Systems Ltd.
	Form 20-F for the year ended December 31, 2007
      Filed May 28, 2008
	File No. 000-28998

Dear Mr. Gaspar:

      We have reviewed your filing and your response letter dated
September 17, 2007 and have the following comments.  Unless
otherwise
indicated, we think you should revise your document in future
filings
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 information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

	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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

      Please respond to confirm that such comments will be
complied
with, or, if certain of the comments are deemed inappropriate,
advise
the staff of your reason.  Your response should be submitted in
electronic form, under the label "corresp" with a copy to the
staff.
Please respond within ten (10) business days.

Form 20-F for the year ended December 31, 2007
Note 19. Major Customer and Geographic Information, page 207

We note from your response to our prior comment number 19 that the
Company`s operations are divided or allocated into a business unit
(BU) structure. We also note that the Company`s chief operating
decision maker (CODM) reviews the various BU`s results (revenues
and
profits) for management purposes as well as for evaluation of
managers` performance, and that resource allocation is performed
on a
per contract basis or a per BU basis. We further note from your
response that discrete financial information is aggregated and
available for the Company`s BUs. Based on this information
contained
in your prior response, it appears that your various business
units
may meet the criteria for an operating segment outlined in
paragraph
10 of SFAS No.131.

Please tell us in further detail how the Company`s operations are
organized into business units and tell us the number of business
units comprising the Company`s operations for the periods
presented
in the Company`s financial statements. As part of your response,
you
should also explain in further detail why you believe that the
Company`s various business units do not represent separate
operating
segments pursuant to paragraph 10 of SFAS No.131 for which the
disclosures outlined in paragraphs 25 through 32 of SFAS No. 131
should be provided. We may have further comment upon receipt of
your
response.


					*******

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Claire Erlanger at (202) 551-3301 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3813 with any other
questions.


Sincerely,



							Linda Cvrkel
Branch Chief




VIA FACSIMILE (212) 704-5918
Ms. Elizabeth Cho
Jenkins & Gilchrist
Mr. Joseph Gaspar
Elbit Systems Ltd.
July 31, 2008
Page 1


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</DOCUMENT>
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