December 10, 2019

Yitschak Barabi
Financial Manager
G WILLI FOOD INTERNATIONAL LTD
4 Nahal Harif St. Northern Industrial Zone
Yavne 81106, Israel

       Re: G WILLI FOOD INTERNATIONAL LTD
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Filed March 27, 2019
           File No. 0-29256

Dear Mr. Barabi:

        We issued comments to you on the above captioned filing on November 5,
2019. As of
the date of this letter, these comments remain outstanding and unresolved. We
expect you to
provide a complete, substantive response to these comments by December 23,
2019.

        If you do not respond, we will, consistent with our obligations under
the federal securities
laws, decide how we will seek to resolve material outstanding comments and
complete our
review of your filing and your disclosure. Among other things, we may decide to
release
publicly, through the agency's EDGAR system, all correspondence, including this
letter, relating
to the review of your filings, consistent with the staff's decision to publicly
release comment and
response letters relating to disclosure filings it has reviewed.

       Please contact Adam Phippen at (202) 551-3336 or Jim Allegretto at (202)
551-3849 with
any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services