SecProbe.io

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Mail Stop 3533
      						December 12, 2005

Mr. Zvi Slonimsky
Chief Executive Officer
Alvarion Ltd.
21A HaBarzel Street
Tel Aviv 69710, Israel

	Re:	Alvarion Ltd.
      Form 20-F for Fiscal Year Ended December 31, 2004
		Filed: June 21, 2005
		File No. 0-30628

Dear Mr. Slonimsky:

      We have reviewed your response letter dated November 30,
2005
and have the following comments.  As noted in our comment letter
dated October 27, 2005, we have limited our review to your
financial
statements and related disclosures and do not intend to expand our
review to other portions of your documents.

Form 20-F for Fiscal Year Ended December 31, 2004
Item 5. Operating and Financial Review and Prospects
A. Operating Results, page 35

1. We have considered your response to comments 2 and 3 of our
letter
dated October 27, 2005.  Please clarify your discussion of sales,
cost of sales and write-off of excess inventory on pages 42, 43
and
44 to reflect your response to this comment and our previous
comments.  In this disclosure please quantify the impact of the
utilization of previously written-off inventory on: sales, cost of
sales, gross margin, operating trends and impact on results of
operations.  Describe the character of those inventories and the
facts and circumstances which led up to the original charge-offs
and
then to the subsequent sales.  In addition, you should provide a
forward looking discussion addressing the likelihood of the
Company
utilizing previously written-off inventory in future operations
and
advise us.

2. Similarly, expand your disclosure of your accounting policies
on
pages 37 and 38 and in the notes to the financial statements to
clearly describe how these sales and inventories are accounted for
and presented in your financial statements.   You should explain
the
conditions necessary for management to reverse a previously
recognized inventory valuation allowance and advise us.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  You may contact
Joseph M. Kempf, Senior Staff Accountant, at (202) 551-3352 or
Robert
S. Littlepage, Accountant Branch Chief, at (202) 551-3361 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3810 with any other
questions.

								Sincerely,

								Larry Spirgel
								Assistant Director
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Mr. Zvi Slonimsky
Chief Executive Officer
Alvarion Ltd.
December 12, 2005
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