November 21, 2005


Fax (972) 9-765-1977
Room 4561


Ilan Erez
Chief Financial Officer
Silicom Ltd.
8 Hanagar Street
Kfar Sava 44000, Israel

      RE: 	Silicom Ltd.
 		Form 20-F for Fiscal Year Ended December 31, 2004
		File No. 000-23288

Dear Mr. Erez:

      We have reviewed the above referenced filing and have the
following comment.  Please note that we have limited our review to
the matters addressed in our comment below. We may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
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.

Item 15. Controls & Procedures, page 62

1. We note your response to prior comment no. 1 where you indicate
you believe the disclosure in Item 15, "based on our evaluation,
which was completed within 90 days of the filing date of this
annual
report," was correct and in compliance with Section F of the SEC`s
Release No. 33-8238.  Section F.3 of the Release states "We are
adopting as proposed the change of the evaluation date for
disclosure
controls to `as of the end of the period` covered by the quarterly
or
annual report." While we note that your CEO and CFO have concluded
that your disclosure controls and procedures were effective as of
the
end of the period covered by your report, you disclosures continue
to
indicate that their evaluation was completed within 90 days of the
filing date of the annual report and not as of the end of the
period
covered by the report as required by Release No. 33-8238.  Tell us
how management`s assessment complied with the requirements of the
Release or revise accordingly.

* * * * *

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.

	You may contact David Edgar, Staff Accountant, at (202)-551-
3459
or the undersigned at (202) 551-3730 if you have any questions
regarding comments on the financial statements and related
matters.

						Sincerely,


						Kathleen Collins
						Accounting Branch Chief


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Ilan Erez
Silicom Ltd.
November 21, 2005
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