SecProbe.io

CORRESP
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                December
                  12, 2005

                FOLEY
                  & LARDNER LLP

                ATTORNEYS
                  AT LAW

                111
                  HUNTINGTON AVENUE

                BOSTON,
                  MASSACHUSETTS 02199

                617.342.4000
                  TEL

                617.342.4001
                  FAX

                www.foley.com

                WRITER’S
                  DIRECT LINE

                617.342.4071

                elefevre@foley.com
                  EMAIL

                CLIENT/MATTER
                  NUMBER

                058767.0101

      VIA
        EDGAR
        AND HAND DELIVERY

      Larry
        Spirgel, Assistant Director

      United
        States Securities and Exchange Commission

      Division
        of Corporation Finance

      100
        F
        Street, N.E.

      Washington
        D.C. 20549

                Re:

                  Scopus
                    Video Networks Ltd.

                  Amendment
                    No. 3 to Registration Statement on Form F-1

                  Filed
                    November 18, 2005

                  File
                    No. 333-129804

      Dear
        Mr.
        Spirgel:

      Scopus
        Video Networks Ltd. (“Scopus” or the “Company”) has filed the above referenced
        Amendment No. 3 to its Registration Statement on Form F-1
        (the “F-1/A”) to (a) revise the bona fide estimate of the initial public
        offering price to between $7.00 and $9.00 per share and (b) include the
        undertakings of Items 512(a)(5)-(6) of Regulation S-K which became effective
        on
        December 1, 2005. We have enclosed a marked copy of the amendment.

      On
        behalf of the Company, we are providing further clarification with respect
        to
        the Company’s belief that a recirculation of the Preliminary Prospectus dated as
        of November 18, 2005 (the “Prospectus”) will not be required in connection the
        F-1/A.

      The
        F-1/A was filed in order to reflect the reduced the anticipated offering
        price
        range for the Ordinary Shares being offered by the Company from $10 to $12
        per
        share as set forth in the Preliminary Prospectus to $7 to $9 per share as
        set
        forth in the F-1/A. Based on the Company's evaluation of the effect of the
        decreased net proceeds to the Company due to the lower anticipated offering
        price, the Company believes that such decrease will not materially affect
        its
        business or operations as disclosed in the Preliminary Prospectus. As indicated
        under “Use of Proceeds”, only $6-10 million of the proceeds are being allocated
        for specific purposes and the balance will be added to working capital. The
        Company has been cash flow positive in each of the past two years and expects
        to
        be cash flow positive, without giving effect to the receipt of the proceeds
        from
        this offering, during 2005. Accordingly, the reduction in the proceeds has
        not
        resulted in the Company changing its expectations as to the adequacy of its
        capital resources, as set forth under “Liquidity and capital resources.” We have
        been advised by the Representatives of the Underwriters that in their opinion
        the reduction in the anticipated offering price range will not be material
        to an
        investment decision by prospective purchasers of the Ordinary Shares.
        Nonetheless, we have confirmed from the underwriters for the offering that
        they
        will, prior to confirming any sales of the Ordinary Shares contact all
        prospective investors to whom it is anticipated that sales of the Ordinary
        Shares will be confirmed, notify such investors of the reduced offering range
        and ask such investors to reconfirm their intent to invest in the
        offering.

      The
        Company intends to verbally request acceleration of the effective time of
        the
        above-referenced Registration Statement so that it may become effective at
        6:00
        p.m., Eastern Time, today, or as soon as possible thereafter. In connection
        with
        the foregoing, please contact us if we can provide any further information
        or
        clarification.

                Very
                  truly yours,

                /s/
                  Edouard C. LeFevre

                Edouard
                  C. LeFevre

              cc:

                Daniel
                  Zimmerman, Staff Attorney

                David
                  Mahlab, Chief Executive Officer

                Paul
                  D. Broude, Esq.

                Gene
                  Kleinhendler, Esq.

                Bruce
                  A. Mann, Esq.

                Aaron
                  M. Lampert, Esq.