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SEC Comment Letter for Allot Ltd. (ALLT) (CIK 0001365767) (ALLT) — Jan 22, 2013

Allot Ltd. (ALLT) (CIK 0001365767)
Date: Jan. 22, 2013 · CIK: 0001365767 · Accession: 0000000000-13-003485

AI Filing Summary & Sentiment

File numbers found in text: 001-33129

Referenced dates: December 11, 2012, December 28, 2012

Date
January 22, 2013
Author
/s/ Patrick Gilmore
Form
UPLOAD
Company
Allot Ltd. (ALLT) (CIK 0001365767)

Letter

January 22, 2013 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, 2011 Filed April 17, 2012 File No. 001-33129

Dear Mr. Hadar :

We have reviewed your letter dated December 28, 2012 in connection with the above - referenced filing an d have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by providing the requested informatio n, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendme nt to your filing and the information you provide in response to this comment, we may have additional comments. Unless otherwise noted , where prior comments are referred to they refer to our letter dated December 11, 2012 .

Form 20 -F for the Fi scal Year Ended December 31, 2011

Consolidated Financial Statements

Note 13: Taxes on Income, page F -38

1. In your response to prior comment 7 you indicate that the $5,419 thousand increase in the deferred tax asset and corresponding increase in the valuat ion allowance should have been presented on a net basis in the same line item. Please tell us what consideration was given to the separately presenting the impact of the valuation allowance in the reconciliation . Please refer to ASC 740-10-50-6.

Rami Hadar Allot Communications Ltd. January 22, 2013 Page 2

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In responding to our comment , please provide a written statement from the compa ny acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing s;

 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 s; 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.

You may contact Joyce Sweeney, Staff Accountant , at (202) 551 -3449 if you have questions regarding comments on the financial statements and related matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3406 .

Sincerely,
/s/ Patrick Gilmore

Show Raw Text
January 22, 2013

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, 2011
Filed April 17, 2012
File No. 001-33129

Dear Mr. Hadar :

We have reviewed your letter dated December 28, 2012  in connection with the above -
referenced filing an d have the following comment.  In our comment , we may ask you to provide
us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested informatio n, or by advising us when you will provide the requested
response.   If you do not believe our comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendme nt to your filing and the information you provide in
response to this comment, we may have  additional comments.   Unless otherwise noted , where
prior comments are referred to they refer to our letter dated December 11, 2012 .

Form 20 -F for the Fi scal Year Ended December 31, 2011

Consolidated Financial Statements

Note 13: Taxes on Income, page F -38

1. In your response to prior comment 7 you indicate that the  $5,419 thousand increase in the
deferred tax asset and corresponding increase in the valuat ion allowance should have
been presented on a net basis in the same line item.  Please tell us what consideration was
given to the separately presenting the impact of the valuation allowance  in the
reconciliation .  Please refer to ASC 740-10-50-6.

Rami Hadar
Allot Communications  Ltd.
January 22, 2013
Page 2

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing s to be certain that the filing s include  the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company  and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment , please provide a written statement from the compa ny
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing s;

 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 s; 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.

You may contact Joyce Sweeney, Staff Accountant , at (202) 551 -3449 if you have
questions regarding comments on the financial statements and related matters.  If you require
further assistance, do not hesitate to contact me at (202) 551 -3406 .

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilmore
Accounting Branch Chief