SecProbe.io

June 28 , 201 9
Via E-mail
Erez Antebi
Chief Executive  Officer
Allot Ltd.
22 Hanagar Street
Neve Ne’eman Industrial Zone B
Hod-Hasharon 45240
Israel

 Re: Allot Ltd.
  Form 20-F for the Fiscal Year Ended December 31, 201 8
  Filed March 1 9, 2019
  File No. 1 -33129

Dear Mr. Antebi :

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 preclude further review by the Assistant Director group with respect
to other issues.   In our comments , we ask you to provide us with information so we may better
understand your disclosur e.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in yo ur response.

After reviewing your response to these  comments, we may have  additional comments.

General

1. Your website provides a section on supported protocols which includes an entry dated
October 19, 2015 for the Allot DART Protocol Pack, and it sta tes that you refined certain
VPN applications including Freegate which is used by millions in several countries
including North Korea.  Third party websites continue to state that Freegate is used in
North Korea.  Also, the transcript of your fourth quarte r 2018 earnings call quotes your
Chief Executive Officer as stating that Vodafone is one of your largest security
customers, and that in December Telefonica launched their service in Spain based on the
Allot NetworkSecure product.  Those companies appear t o offer telecommunications
services in Syria and Sudan.  Syria, Sudan and North Korea are designated by the U.S.
Department of State as state sponsors of terrorism and are subject to U.S. economic
sanctions and/or export controls.  Your Form 20 -F does not provide disclosure about

Erez Antebi
Allot Ltd.
 June 28, 2019
 Page 2

 those countries.  Please describe to us the nature and extent of any past, current, and
anticipated contacts with Syria and Sudan, and with North Korea  since November 20,
2017, the date that it was designated, including with their governments, whether through
subsidiaries, distributors, resellers, affiliates, or other direct or indirect arrangements.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filin g includes 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 comments, please provide  a written 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.

You may contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 -
3470 if you have any questions about the comments or our review.

Sincerely,

 /s/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  Alberto Sessa
  Chief Financial Officer

  Barbara Jacobs
  Assistant Director