SecProbe.io

Mail Stop 3030
November 14, 2017

Via E -mail
Arie Trabelsi
Chief Executive Officer
SuperCom  Ltd.
1 Arie Shenkar Street
Hertzliya Pituach 4672514,  Israel

 Re: SuperCom  Ltd.
  Form 20-F for the Fiscal Year Ended December 31, 2016
  Filed May 24, 2017
Amendment No. 1 to Form 20 -F for the Fiscal Year
 Ended December 31, 2016
Filed May 25 , 2017
File No. 1-33668

Dear Mr. Trabelsi :

We have reviewed your filing an d 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 busine ss days by providing the requested
information or advis e 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.

Amendment No. 1 to Form 20 -F for the Fiscal Year Ended December 31, 2016

Item 5.  Operating and Financial Review and Prospects

Year Ended December 31, 2016 Compare d with Year Ended December 31, 2015

Revenues, page 30

1. We note that your revenue decreas ed by approximately $8.3 million from 2015 to
2016 .  While we note from your disclosure that revenue decreased by approximately
$14 million due to near completion of projects in your e -ID division, and it appears that
those revenue losses were partially of fset by revenue gains from other divisions, it is not

Arie Trabelsi
SuperCom  Ltd.
November 14 , 2017
Page 2

 clear how you have accounted for all material changes in your revenues for the periods
presented.   Please tell us what the numbers in the last sentence of this paragraph represent
in terms of dollar amo unts and show us how those revenue gains, combined with your
revenue losses, account for all material changes in your revenue for the periods
presented.   In addition, revise future filings to clearly disclose and quantify the reasons
underlying each material change in your revenues for the periods presented.

Expenses, page 30

2. You present the non -GAAP measure operating expenses excluding gain from bargain
acquisition and discuss changes based on this non -GAAP measure, but you do not
identify them as non-GAAP measures, nor do you provide the reconciliations to the most
directly comparable GAAP measure and the qualitative disclosures required by Item
10(e) of Regulation S -K.  Please revise your presentations in future filings to comply
with that guidanc e.

Item 18.   Financial Statements

Consolidated Statements of Operations, page F -2

3. Revise future filings to present the amount of revenues and cost of revenues separately
for your products and services.   We note from page F -28 that you generate revenues from
product sales of raw materials and equipment, as well as from the sale of services of
electronic monitoring, treatment programs, maintenance, royalties and project
management. Please refer to Rules 5 -03(b)(1) and (2) of Regulation S -X.

Note 2: Signif icant Accounting Policies

k. Revenue Recognition, page F -9

4. We note on page 36 that for your e -ID and security business you recognize royalties
when the license issuances are reported to you, usually on a monthly basis. Please tell us
how you recognize re venue for these royalties when the license issuances are not reported
to you. Revise this note in future filings to specifically disclose your revenue recognition
policy for these license issuances.

Note  5: Acquisition,  page F -15

5. We note that you recorded bargain purchase gains on the acquisitions of Safend Ltd. and
Alvarion Technologies Ltd. during fiscal 2016.   Describe to us, in sufficient detail, the
reassessment you performed pursuant to ASC 805 -30-25-4 before recognizing the gain
on bargain purchase.

Arie Trabelsi
SuperCom  Ltd.
November 14 , 2017
Page 3

 6. Describe to us how you determined the $1.425 million fair value of consideration
transferred for the acquisition of Alvarion Technologies Ltd. Refer to ASC 805 -30-30-7
and 30 -8.

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 David Burton at (202) 551 -3626 o r me at  (202) 551 -3662 if you have
questions regarding comments on the financial statements and related matters.  Please contact
Tim Buchmiller  at (202) 551 -3635 or Geoff Kruczek , Senior Attorney , at (202) 551 -3641 with
any other questions.

Sincerely,

 /s/ Ke vin J. Kuhar

Kevin J. Kuhar
Accounting Branch Chief
Office of Electronics and Machinery