SecProbe.io

November 19, 2024
Grant Highlander
Chief Financial Officer
Verint Systems Inc.
175 Broadhollow Road
Melville, New York 11747
Re:Verint Systems Inc.
Form 10-K for the Fiscal Year Ended January 31, 2024
File No. 001-34807
Dear Grant Highlander:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the period ended January 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of Operations
Revenue, page 39
1.With a view towards enhanced investor understanding, in future filings please provide
a quantified discussion of customer migrations from non-SaaS solutions to SaaS
solutions.
2.We note the increase in professional services and other revenue resulted primarily
from recognition of patent license royalty revenue in the current period for royalties
that were previously underreported by a licensee partially offset by a decrease in
implementation services. Please provide us with a comprehensive explanation of the
factors that contributed to the sales being reported out-of-period. In your response,
please tell us the amount of previously underreported revenue that was recognized in
the period, which periods are covered by the past sales, the processes followed by
existing licensees and the controls in place to ensure that patent license royalty
revenue from your existing licensees is reported on a timely basis.

November 19, 2024
Page 2
Consolidated Financial Statements
Consolidated Statements of Operations, page 58
3.We note nonrecurring revenue consists of revenue from perpetual licenses, hardware
sales, installation services, business advisory consulting and training services, and
patent license royalties. Please revise your income statement presentation to
separately report sales of tangible products, revenues from services, and other
revenues pursuant to Rule 5-03.1 of Regulation S-X. Similarly revise your reporting
of cost of revenue pursuant to Rule 5-03.2 of Regulation S-X.
            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.
            Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202-
551-3361 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology