<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                            November 28, 2018

Asaf Berenstin
Chief Financial Officer
Magic Software Enterprises Ltd.
5 HaPlada Street
Or-Yehuda, Israel 6021805

       Re: Magic Software Enterprises Ltd.
           Form 20-F for the Fiscal Year Ended December 31, 2017
           Filed April 30, 2018
           Form 6-K
           Filed September 21, 2018
           File No. 000-19415

Dear Mr. Berenstin:

       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 6-K filed September 21, 2018

Exhibit 99.1
Notes to Unaudited Condensed Interim Consolidated Financial Statements
Note 2. Basis of Presentation and Summary of Significant Accounting Policies
General
Changes in Accounting Policies, page F-10

1.    We note that you provide IT professional services on a fixed price or
time and materials
      basis. We also note your disclosure related to your accounting for
contracts that involve
      significant customization to customer-specific specifications. Please
tell us if you
      provide IT professional services that do not involve significant
customization and, if so,
      revise to disclose your accounting for these services.
2.    Please tell us if additional sales commissions are paid upon contract
renewal and, if so,
 Asaf Berenstin
Magic Software Enterprises Ltd.
November 28, 2018
Page 2
         whether such amounts are commensurate with the initial commissions. In
addition,
         explain how commissions paid for renewals are considered in your
initial commission
         amortization period and the period of time over which you amortize
commission costs
         related to contract renewals. Refer to ASC 340-40-35-1 and 340-40-50.
Ensure that
         disclosures in future filings clearly describes your policy.
Note 3. Revenue Recognition, page F-12

3.       We note your disclosure of the impact of ASC 606 on your condensed
interim
         consolidated statements of income and balance sheets, however, the
disclosures seems
         limited to only some of your revenue and the reasons for the
difference is not clearly
         identified. Tell us and revise future filings to provide the detailed
disclosures that are
         outlined by ASC 606-10-65-1(h) and 65-1(i).
       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 Diane Fritz, Staff Accountant, at (202) 551-3331 or
Stephen Krikorian,
Branch Chief, at (202) 551-3488 with any questions.



                                                                Sincerely,
FirstName LastNameAsaf Berenstin
                                                                Division of
Corporation Finance
Comapany NameMagic Software Enterprises Ltd.
                                                                Office of
Information Technologies
November 28, 2018 Page 2                                        and Services
FirstName LastName
</TEXT>
</DOCUMENT>
