SecProbe.io

April 16, 2020
James Moylan, Jr.
Sr. Vice President, Finance and Chief Financial Officer
CIENA CORP
7035 Ridge Road
Hanover, MD 21076
Re:CIENA CORP
Form 10-K for the Fiscal Year Ended November 2, 2019
Filed on December 20, 2019
File No. 1-36250
Dear Mr. Moylan:
            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 10-K for the Fiscal Year Ended November 2, 2019
Item 8. Financial Statements and Supplemental Data
General, page 60
1.Please revise your future filings to present your financial statements, including your
primary financial statements as well as the notes thereto, and all other financial
information in the filings as of and for the periods ended on the actual dates on which your
fiscal years and quarterly periods end. In addition, revise the face of your Forms 10-K and
10-Q in future periods to correctly indicate the actual dates on which your fiscal years and
quarterly periods end.

 FirstName LastNameJames Moylan, Jr.
 Comapany NameCIENA CORP
 April 16, 2020 Page 2
 FirstName LastName
James Moylan, Jr.
CIENA CORP
April 16, 2020
Page 2
Item 9A. Controls and Procedures
Report of Management on Internal Control Over Financial Reporting, page 108
2.Please confirm that your management performed its assessment and concluded on the
effectiveness of your internal control over financial reporting as of November 2, 2019 and
revise this report in future filings to assess and conclude on the effectiveness of your
internal control over financial reporting as of the actual date on which your fiscal year
ends.  We note that your auditors have correctly audited and opined on the effectiveness
of your internal control over financial reporting as of November 2, 2019.
            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 Mindy Hooker at (202) 551-3732 or Martin James, Senior Advisor, at
(202) 551-3671 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing