SecProbe.io

January 6, 2012

Via E-mail
Rami Hadar  Chief Executive Officer and President 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, 2010
  Filed June 9, 2011   File No. 1-33129
Dear Mr. Hadar:

We have limited our review of your filing to your  contacts with countries that have been
identified as state sponsors of terrorism, and we  have the following comments.  Our review with
respect to this issue does not prec lude further review by the Assist ant Director group with respect
to other issues.   At this juncture, we are asking you to provide us with information so we may
better understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts and circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.   General

1. We are aware of recent news reports, includi ng the article discussed in the press release
attached to your Form 6-K filed on December 23, 2011, indicating that since 2006 you have sold Internet-surveillance equipment to a Danish distributor who then shipped it to
Iran.  Iran is designated as a state sponsor of terrorism by th e U.S. Department of State,
and is subject to U.S. economic sanctions and export controls.  Please describe to us the
nature, duration, and extent of your past, cu rrent, and anticipated contacts with Iran,
whether through subsidiaries, di stributors, resellers, or other direct or indirect
arrangements.  Your response should descri be any products, equipment, components,
technology, software, information, support, and services that you have  provided or intend
to provide into Iran, directly or indi rectly, and any agreements, commercial
arrangements, or other contact s you have had with the govern ment of Iran or entities

Rami Hadar Allot Communications Ltd. January 6, 2012 Page 2
 controlled by that government.  Please addres s specifically the afor ementioned reports of
the indirect sales of your products to Iran.

2. You disclose on pages 24, 28, and elsewhere that you operate in Latin America, the
Middle East, and Africa, regi ons that can be understood to  include Cuba, Syria, and
Sudan, which are designated as state sponsor s of terrorism by the U.S. Department of
State and are subject to U.S. economic sanctio ns and export controls.  Please describe to
us the nature and extent of your past, current , and anticipated contacts with Cuba, Syria,
and Sudan, if any, whether through subsidiaries, distributors, rese llers, or othe r direct or
indirect arrangements.  Your response should describe any products, equipment,
components, technology, software, informa tion, support, and serv ices that you have
provided, or intend to provide, into those countries, direct ly or indirectly, and any
agreements, commercial arrangements, or other contacts you have had with their
governments or entities cont rolled by those governments.

3. You state in the aforementioned Form 6-K that  your “products are not defense items and
are designed and intended for the civil market.”   Please tell us whet her, to the best of
your knowledge, understanding, and belief, a ny products, equipment, components,
software, or technology you have provided or intend to provide,  directly or indirectly,
into Cuba, Iran, Sudan, and/or Syria, includ ing the products reporte dly shipped to Iran by
the Danish distributor, have pot ential non-civilian uses, and describe such possible uses
of which you are aware.  Also, advise us  whether, to the best of your knowledge,
understanding, and belief, any such items have  been put to non-civilian uses by Cuba,
Iran, Sudan, and/or Syria, and discuss a ny such uses of which you are aware.

4. You state in the aforementioned Form 6-K that  your “corporate policy is to comply fully
with Israeli and non-Israeli laws , including all applicable expo rt laws and regulations.”
Please describe for us your current policies, procedures, and systems, if any, to ensure
compliance with U.S. economic sanction laws and export control regul ations, and tell us
whether you have undertaken any additional measures or implemented enhanced controls in light of the reported shipment s of your products to Iran.

5. Please discuss for us the materiality of any contacts with Cuba, Iran, Sudan, and Syria
you describe in response to the foregoi ng comments, and whether those contacts
constitute a material investment risk for your security holders.  You should address
materiality in quantitative terms, incl uding the approximate dollar amounts of any
associated revenues, assets, and liabilities for the last three fiscal years and the
subsequent interim period.  Also, address mate riality in terms of qua litative factors that a
reasonable investor would deem important in  making an investment decision, including
the potential impact of corpor ate activities upon a company’s reputation and share value.
As you know, various state and municipal govern ments, universities, and other investors
have proposed or adopted divestment or si milar initiatives rega rding investment in
companies that do business with U.S.-desi gnated state sponsors of  terrorism.  Your
materiality analysis should address the pot ential impact of the investor sentiment

Rami Hadar Allot Communications Ltd. January 6, 2012 Page 3
 evidenced by such actions directed toward co mpanies that have contacts with Cuba, Iran,
Sudan, or Syria.  In this regard, you shoul d discuss specifically the above-referenced
news reports about your produc ts being shipped to Iran.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts rela ting to the company’s disclosure , they are responsible for the
accuracy and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:

 the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.
 Please contact Pradip Bhaumik, Special Couns el, at (202) 551-3333 or  me at (202) 551-
3470 if you have any questions abou t the comments or our review.

        S i n c e r e l y ,
         /s/ Cecilia Blye          C e c i l i a  B l y e ,  C h i e f          Office of Global Security Risk  cc:  Barbara Jacobs   Assistant Director  Division of Cor poration Finance