April 2, 2019

Stephen Spengler
Chief Executive Officer
Intelsat S.A.
4 rue Albert Borschette
Luxembourg
Grand-Duchy of Luxembourg L-1246

       Re: Intelsat S.A.
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Filed February 20, 2019
           File Number 001-35878

Dear Mr. Spengler:

       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, 2018

Notes to the Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
(c) Revenue Recognition, page F-10

1.    Please tell us and revise your future filings to disclose the measure of
progress associated
      with each type of product and service revenue. Please tell us how you
determined that
      these methods provide a faithful depiction of the transfer of goods or
services to the
      customer. Please refer to ASC 606-10-25-31 through 25-33 and ASC
606-10-50-18.
 Stephen Spengler
FirstName LastNameStephen Spengler
Intelsat S.A.
Comapany NameIntelsat S.A.
April 2, 2019
Page 2,
April 2 2019 Page 2
FirstName LastName
2.       You disclose on page 47 that the pricing of your services is generally
fixed for the
         duration of the service commitment. For each service type, please tell
us and revise your
         future filings to disclose if the total contract price is fixed or if
the price per unit of goods
         or services transferred is fixed (and the number of units transferred
may be variable).
         Please refer to ASC 606-10-50-12(b).
3.       We note your disclosure on page F-12 that when more than one party is
involved in
         providing good or services to a customer, you generally recognize the
transaction on a
         gross basis. Please clarify the nature of the goods and services for
which you recognize
         revenue on a gross basis and those for which you recognize revenue on
a net basis. In
         addition, provide us with a comprehensive analysis regarding how you
concluded you
         were the principal or agent in the related arrangements. Please refer
to ASC 606-10-50-
         12(c) and ASC 606-10-55-36 through 55-40.
       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 Robert Shapiro, Senior Staff Accountant, at (202)
551-3273 or Lisa
Etheredge, Senior Staff Accountant, at (202) 551-3424 with any questions.



                                                                  Sincerely,

                                                                  Division of
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