SecProbe.io

July 24, 2013

Via E -mail
Arie Trabelsi
Chief Executive Officer
SuperCom Ltd.
The Nolton House
14 Arie Shenkar Street
Herzliya Pituach 4672514, Israel

Re: SuperCom Ltd.
Registration Statement on Form F -1
Filed July 3, 2013
 File No.  333-189810

Dear Mr. Trabelsi:

We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information.   Where you do not believe our comments apply to your facts and
circumstances o r do not believe a n amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.

Registratio n Statement

1. Please amend your filing to include all information other than that which can be omitted
as provided by Rule 430A.  For example, we note the blanks currently on the prospectus
cover  and on page 5 regarding the number of securities you are offering.
2. Your disclosure currently indicates both that the offering will be made on a best efforts
basis and that it will be underwritten.  Please revise to clarify and to include all
information require d by Item 9.B of Form 20 -F, which should be provided in response to
Item 4.a of Form F -1.  If the offering is to be underwritten, please clearly describe the
nature of the underwriter’s obligation and file your agreement or proposed form of
agreement per Item 601(b)(1) of Regulation S -K.

Arie Trabelsi
SuperCom Ltd.
July 24, 2013
Page 2

 Exhibits
3. Please file the exhibit required by Regulation S -K Item 601(b)(5).

Signatures

4. Please clearly indicate below the second paragraph of text required on the Form F -1
Signatures page who signed the document in the capacity of principal financial officer,
controller or principal accounting officer.  Refer to Instruction 1 to the Form F -1
Signatures page.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s  disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement  please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not forec lose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the Un ited States.

Please refer to Rules 460 and 461 regarding request s for acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.   Please allow
adequate time for us to review any amendment prior to the request ed effective date  of the
registration statement .

Arie Trabelsi
SuperCom Ltd.
July 24, 2013
Page 3

 Please contact Tom Jones at (202) 551 -3602 or Mary Beth Breslin,  Senior Attorney, at
(202) 551 -3625 with any questions.

 Sincerely,

/s/ Mary Beth Breslin for
.
 Amanda Ravitz
 Assistant Director

cc (via e -mail): Steven C. Glusband, Esq.