Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue of the Americas
New York, New York 10019-6064
April 10, 2013
Via EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attn: Ajay Koduri
Intelsat Global Holdings S.A.
Registration Statement on Form F-1 (File No. 333-181527)
Ladies and Gentlemen:
On behalf of our client, Intelsat Global Holdings S.A., a Luxembourgsociété anonyme (the “Company”), we have separately transmitted for filing with the Securities and Exchange Commission (the “Commission”) in electronic form Amendment No. 9 (“Amendment No.9”) to the above-referenced Registration Statement on Form F-1 (the “Registration Statement”), marked to show changes made since Amendment No. 8 to the Registration Statement.
In response to our telephone conversations with the Staff of the Commission, the Company has revised pages 11 and 55 of the Registration Statement to provide additional balancing disclosure regarding its expected results of operations for the three months ended March 31, 2013.
Should you have any questions regarding the Registration Statement, please feel free to contact John C. Kennedy at (212) 373-3025, Brian M. Janson at (212) 373-3588 or the undersigned at (212) 373-3309.
Very truly yours,
/s/ Raphael M. Russo
Raphael M. Russo
| cc: | Michelle V. Bryan, Esq. |
Intelsat Global Holdings S.A.
| Raymond Y. Lin, Esq. |
Latham & Watkins LLP
