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SEC Comment Letter for Allot Ltd. (ALLT) (CIK 0001365767) (ALLT) — Jan 6, 2010

Allot Ltd. (ALLT) (CIK 0001365767)
Date: Jan. 6, 2010 · CIK: 0001365767 · Accession: 0000000000-10-001031

AI Filing Summary & Sentiment

File numbers found in text: 001-33129

Referenced dates: December 18, 2009, November 25, 2009

Date
January 6, 2010
Author
Not clearly detected
Form
UPLOAD
Company
Allot Ltd. (ALLT) (CIK 0001365767)

Letter

Mail Stop 4561 January 6, 2010 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 your response letter dated December 18, 2009 in connection with 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 deta iled as necessary in your expl anation. In some of our comments, we may ask you to provide us w ith supplemental information so we may better understand your disclosure. After re viewing this information, we may raise additional comments. Unless otherwise noted, where prior comments are referred to they refer to our letter dated November 25, 2009. Form 20-F for the Fiscal Year Ended December 31, 2008

General 1. As previously requested, provide a st atement 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 a ny action with respect to the filing; and • the Company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any pers on under the federal s ecurities laws of the United States.

Rami Hadar Allot Communications Ltd. January 6, 2010 Page 2 2. Please refer to prior comment 5. We note that you requested confidential treatment pursuant to Rule 83 of the Freedom of Information Act for information contained in the separately provided lette r referenced in your response. Please note that Rule 83 sets forth the procedures for a registrant to request confidential treatment for information contained in a response letter or for supplemental information provided to us. If you seek to rely upon this rule, the response letter submitted electronically must, on each page where you omit information from the electronic version of the letter, desi gnate or mark the place where you omit material and tie the omission to a legend that indicates material has been omitted and provide any other required information. Note that the rule also requires you to clearly mark each page with the wo rds “Confidential Treatment Requested by [name]” and an identifying number and code, such as a Bates-stamped number. Further, in your written request for confidential treatment, you must refer to the record by the identifying number and code. If you wish to rely on this rule, please re-file your correspondence on EDGAR acco rdingly and resubmit a confidential treatment request that conforms to the rule.

* * * * * * *

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. 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 further 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 Accounting Branch Chief

Rami Hadar Allot Communications Ltd. January 6, 2010 Page 3

Show Raw Text
Mail Stop 4561         January 6, 2010   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 your response letter  dated December 18, 2009 in connection
with 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 deta iled as necessary in your expl anation.  In some of our
comments, we may ask you to provide us w ith supplemental information so we may
better understand your disclosure.  After re viewing this information, we may raise
additional comments.  Unless otherwise noted, where prior comments are referred to they
refer to our letter dated November 25, 2009.    Form 20-F for the Fiscal Year Ended December 31, 2008

General
1. As previously requested, provide a st atement 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 a ny action with respect to the filing;
and
• the Company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

Rami Hadar
Allot Communications Ltd.
January 6, 2010 Page 2  2. Please refer to prior comment 5.  We note that you requested confidential
treatment pursuant to Rule 83 of the Freedom of Information Act for information contained in the separately provided lette r referenced in your response.  Please
note that Rule 83 sets forth the procedures  for a registrant to request confidential
treatment for information contained in a response letter or for supplemental
information provided to us.  If you seek to rely upon this rule, the response letter
submitted electronically must, on each page  where you omit information from the
electronic version of the letter, desi gnate or mark the place where you omit
material and tie the omission to a legend that indicates material has been omitted
and provide any other required information.  Note that the rule also requires you
to clearly mark each page with the wo rds “Confidential Treatment Requested by
[name]” and an identifying number and code, such as a Bates-stamped number.  Further, in your written request for confidential treatment, you must refer to the record by the identifying number and code.  If you wish to rely on this rule, please
re-file your correspondence on EDGAR acco rdingly and resubmit a confidential
treatment request that conforms to the rule.

* * * * * * *

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.
 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 further 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
Accounting Branch Chief

Rami Hadar
Allot Communications Ltd. January 6, 2010 Page 3