SecProbe.io

Mail Stop 4561         November 25, 2009  Rami Hadar, Chief Executive Officer
Allot Communications Ltd. 22 Hanagar Street Neve Ne’eman Industrial Zone B  Hod-Hasharon 45240 Israel
Re: Allot Communications Ltd.
 Form 20-F for the Fiscal Year Ended December 31, 2008
Filed May 7, 2009
 File No. 001-33129

Dear Mr. Hadar:

We have reviewed the above-referenced filing and have the following comments.
If indicated, we think you should revise your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with supplemental information so
we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.

Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
Form 20-F for the Fiscal Year Ended December 31, 2008

Item 3: Key Information

Risk Factors

Certain hardware components for our produc ts come from single or limited sources,
page 9
1. You state that certain hardware components that are us ed in your products are
obtained from single or lim ited sources.  Please tell us how you determined that

Rami Hadar
Allot Communications Ltd.
November 25, 2009 Page 2
the limited source supplier agreement with the companies you cite in this risk factor need not be filed as exhibits pursuant  to Instruction 4(b)(ii) to the Exhibits.

ITEM 15: Controls and Procedures

(a) Disclosure Controls and Procedures, page 97
2. We note that your certifying officers concluded that you “have in place effective
controls and procedures . . . .”  Pleas e refer to Item 15T(a) of Form 20-F and
confirm, if true, that your “disclosure controls and procedures” were effective
during the relevant period and conf irm that you will provide conforming
disclosure in future filings.
3. You state that your Chief Executive Of ficer and Chief Financial Officer
concluded that you “have in place effectiv e controls and procedures designed to
ensure that information disclosed by [ you] in the reports [you] file or submit
under the Exchange Act and the rules thereunder, is recorded, processed,
summarized and reported within the time periods specified in the SEC’s rules and
forms.”  This effectiveness conclusion is stated in terms that are more limited in scope than the definition of “disclosure controls and procedures” as set forth in Exchange Act Rule 13a-15(e).  In your res ponse letter, please confirm, if true, that
your disclosure controls and procedures were also effective to ensure that
information required to be disclosed in the reports that you file or submit under
the Exchange Act is accumulated an d communicated to your management,
including your Chief Executive Officer  and Chief Financial Officer, as
appropriate to allow timely decisions re garding required disclosure.  In future
filings, to the extent you in clude a definition of disclosu re controls and procedures
in your effectiveness conclusion, please incl ude the entire defin ition as set forth in
Exchange Act Rule 13a-15(e).

Changes in Internal Control over Financial Reporting, page 98

4. While you state that no “material changes” in your internal cont rol over financial
reporting occurred during the fiscal year ended 2008 that materially affected your
internal control over financ ial reporting, please note th at Item 15T(c) requires
disclosure of “any change” in your intern al control over financial reporting that
has materially affected or is reasonably likely to materially affect, your internal
control over financial reporting.  Please confirm that there were no changes in
your internal control over financial reporti ng that materially affected, or were
reasonably likely to materially affect your  internal control over financial reporting
and provide us with a representation that you will provide conforming disclosure
in future filings.

Rami Hadar
Allot Communications Ltd.
November 25, 2009 Page 3  Financial Statements

 Notes to Consolidated Financial Statements

 Note 2 – Significant Accounting Policies

 l.  Revenue recognition, page F-13

5. We note your disclosure that vendor-sp ecific objective evid ence (“VSOE”) of
your maintenance and support services is based on the “price when sold
separately.”  Please describe, in deta il, your methodology for establishing VSOE.
If VSOE is based on stated renewal rate s then please tell us how you determined
the renewal rates are substantive.  In this regard, please provide the range of
renewal rates and tell us wh at percentage of your cu stomers actually renew at
such rates.  Alternatively, if VSOE is ba sed on stand-alone sales, then provide the
volume and range of stand alone sales us ed to establish VSOE.  Also, please
describe the various factors that affect  your VSOE analysis including customer
type and other pricing factors (e .g., geographic region, purchase volume,
competitive pricing, perpetual versus term license, etc.).
 Note 3 – Acquisitions, page F-19

6. We note several references throughout your Form 20-F to third party valuations.
For example, on page F-20 you indicate that  the fair value of intangible assets
acquired was based on third-party valuati on.  Also, on page F-21 you indicate that
a third party valuation was used to determine the fair value of certain auction rate securities.  For each reference to a third party valuation in your Form 20-F please describe for us the nature and extent of the third party valuation firm’s involvement in the transaction.  Plea se see Question 141.02 of our Compliance
and Disclosure Interpretations available at http://www.sec.gov/divisions/c orpfin/guidance/sasinterp.htm  for guidance.

* * * * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.

Rami Hadar
Allot Communications Ltd. November 25, 2009 Page 4
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact David Edga r, Staff Accountant, at (202) 551-3459, or Christine
Davis, Assistant Chief Accountant, at (202) 551-3408 if you have any questions
regarding comments on the fina ncial statements and relate d matters.  Please address
questions regarding all other comments to St ephani Bouvet, at (202) 551-3545 or Maryse
Mills-Apenteng, Special Counsel at (202) 551- 3457.  If you need furt her assistance, you
may contact me at (202) 551-3406.
        S i n c e r e l y ,           P a t r i c k  G i l m o r e
        A c c o u n t i n g  B r a n c h  C h i e f