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December 28, 2012

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street Northeast

Washington, DC 20549

 Attn: Patrick Gilmore, Accounting Branch Chief

Re:      Allot
Communications Ltd.

Dear Mr. Gilmore:

On behalf of our client, Allot Communications
Ltd., an Israeli company (the “Company”), please find set forth below for review by the Staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) the Company’s responses to the Staff’s
comment letter dated December 11, 2012 (the “Comment Letter”) with respect to the above-referenced filings of
the Company under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). For ease of reference,
each comment contained in the Comment Letter is printed below in bold text and is followed by the Company’s response. The
information included herein has been provided to us by management of the Company.

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

Information on Allot

Business Overview

Channel Partners, page 23

1.	Your disclosure indicates that “[a] significant
portion” of your sales occur through your channel partners. Please advise and clarify in future filings what the term “significant
portion” means. Further, your Form 20-F states that your agreements with channel partners are usually for a one-year term
and can be terminated by either party after expiration of the initial term. Please clarify whether you have any material agreements
with your channel partners other than as described and if so whether you are substantially dependent upon any of the agreements
for purposes of filing them as exhibits pursuant to Instruction 4(b)(ii) as to exhibits to Form 20-F.

        Securities and Exchange
        Commission

    December 28, 2012

Response:

Approximately one half of the Company’s
revenues in 2011 were derived from direct sales and approximately one half from sales made to channel partners. The Company’s
channel partners consist of systems integrators and OEMs that resell to large and medium size operators and distributors that sell
to smaller operators and to enterprises, often through an additional reseller. The Company confirms that it will disclose this
breakdown in its next Form 20-F filing for the 2012 fiscal year.

The Company informs the Staff that no individual
channel partner accounted for more than 7% of the Company’s total revenues in 2011 and the Company does not currently expect
that any individual channel partner will account for more than that amount in 2012. Accordingly, the Company confirms that it is
not party to any agreement with a channel partner upon which it is substantially dependent and that requires filing pursuant to
Instruction 4(b)(ii) referenced above.

Principal Accountant Fees and Services, page 73

2.	Please describe for us the nature of the audit-related
due diligence investigation services and the fees related to government incentives, outlining the specific services provided by
your principal accountant as well as management’s involvement. Please refer to Rule 2- 01(c) of Regulation S-X and PCAOB
ET Section 101-3.

Response:

With respect to the due diligence investigation
services, in connection with a potential acquisition that was being considered by the Company, the Company’s auditors rendered
services to the Company in three areas:

(1) 	The auditors reviewed the assessments
made by management of the Company with respect to the impact of the potential acquisition on the Company’s financial statements,
including the accounting implications, as well as the potential filing obligations with the Securities and Exchange Commission.

(2) 	The auditors assisted management
of the Company in assessing the impact on the potential acquisition on the Company’s funding from the Israeli Office of the
Chief Scientist.

(3)	The final area with which the auditors assisted management
of the Company was with respect to the tax implications of the potential acquisition.

    2

        Securities and Exchange
        Commission

    December 28, 2012

With respect to non-tax government incentives,
the Company’s auditors reviewed the application and submissions made by the Company to the Israeli Office of the Chief Scientist
in order to receive grants for the Company’s research and development activities. Management is ultimately responsible for
these submissions. The auditors (1) ensure that the submissions are in compliance with the applicable guidelines, which include
numerous technical requirements, (2) attend the Company’s meetings with the government representatives at which the Company
presents facts related to the project; no voting on the incentives takes place at such meetings, and (3) review the Company’s
incentive approvals and ensure that the Company is compliant with filing requirements.

The Company considered each of these services
in advance and each was pre-approved by the Company’s audit committee and provided pursuant to a separate engagement letter.
The Company notes that none of these services is a prohibited non-audit service pursuant to Rule 2-01(c) of Regulation S-X or within
PCAOB ET Section 101-3. Furthermore, with respect to the due diligence services, Section 101-3 expressly permits an auditor to
“Assist in analyzing the effects of proposed transactions including providing advice to a client during negotiations with
potential buyers, sellers, or capital sources.” In each case, the Company’s Chief Financial Officer was responsible
for overseeing the services provided. With respect to assistance in preparing the Company’s submissions to the Office of
the Chief Scientist, the Company considered whether the services would impair the auditors’ ability to act independently,
including whether the auditors would be performing management functions or making management decisions. The Company’s audit
committee and the auditors concluded that no such concerns would be raised. Finally, the Chief Financial Officer, to the extent
necessary, evaluated the adequacy of the services and the findings, and accepted responsibility with respect to the results of
the services. The Company maintains its own internal controls with respect to each of the above-listed items.

Consolidated Financial Statements

Note 2: Significant Accounting Policies

l. Revenue recognition, page F-18

3.	In your disclosure on page F-19 regarding the adoption
of the guidance of ASU 2009-14, you conclude that the company is out of the scope of Subtopic 985-605. Please tell us what consideration
was given to clarifying the treatment of software add-on components, such as ServiceProtector.

Response:

The Company’s traffic management devices
consist of the Allot Service Gateway Platform and the NetEnforcer. These devices provide traffic prioritization and quality of
service optimization, as well as other functionalities, such as security threat blocking, media caching, and real-time and offline
usage-based charging. The devices include a hardware component that is manufactured to Allot’s specifications and that has
embedded software capabilities. The hardware cannot be used without the software and the software cannot be run on any other vendor’s
hardware. A customer may purchase the Company’s traffic management device with the basic capabilities of traffic prioritization
and quality of service optimization. In addition, the customer may choose to purchase additional capabilities/ functionality to
be included in the traffic management device as described below.

    3

        Securities and Exchange
        Commission

    December 28, 2012

The value added services as described on
page 22 of the Form 20-F are the Service Protector, MediaSwift and WebSafe. These value added services are provided as “add-on
components” to the traffic management devices. Customers generally purchase the add-on component with their initial purchase
of the traffic management device.  The add-on components are comprised of software and non-software elements that are integrated
into the traffic management devices.

The add-on components consist of additional
software elements that are embedded on a hardware appliance or a blade that is integrated into the traffic management device or
already embedded in the Company’s basic traffic management device.

Upon the adoption of the guidance of ASU
2009-14, the Company considered whether these add-on components were out of the scope of Subtopic 985-605. As described above,
the add-on components consist of both a hardware and a software component that together deliver the essential functionality of
the add-on component and are integrated into the Company’ traffic management devices. The software of the add-on component
cannot function without the related hardware blade/appliance which is integrated into the traffic management device. The software
of the add-on component is not capable of operating on the hardware of another vendor. The add-on components function together
with the tangible products (traffic management devices) to deliver the product’s essential functionality. Accordingly, the
Company concluded that the add-on components are out of the scope of Subtopic 985-605.

4.	We note your disclosure that the company provides a
provision for product returns and stock rotation. We further note your disclosure on page 11 that if you “encounter significant
product problems, [you] could experience, among other things, loss of major customers, cancellation of product orders, increased
costs, delay in recognizing revenues and damage to [y]our reputation.” Please tell us what consideration was given to disclosing
performance-, cancellation-, termination-, and refund-type provisions related to your multiple-element arrangements. Tell us what
consideration was given to describing the impact of such provisions on your revenue recognition. Please refer to ASC 605-25-50-2.

Response:

The Company
generally does not grant a right of return to its customers. However, the Company has granted a small number of its distributors
“stock rotation rights” with respect to 10% - 20% of the dollar value of purchases made in the previous quarter. In
such instances, the Company recorded a provision for stock rotation returns. The provision for stock rotation rights as of December
31, 2011 and 2010 was de minimus. In addition, from time to time, the Company has agreed to accept product returns from
its customers.  In accordance with ASC 605, “Revenue Recognition”, the Company records a provision for product
returns at the time product revenues are recognized based on the Company’s experience with historical returns and credits
in the previous three years. The Company’s provision for returns is insignificant and has represented approximately one percent
of revenues recognized for the years ended December 31, 2011 and 2010 ($729,000 and $726,000 as of December 31, 2011 and 2010,
respectively).

    4

        Securities and Exchange
        Commission

    December 28, 2012

The Company’s multiple element arrangements
generally do not include cancellation, termination for convenience or refund type provisions. Certain multiple element arrangements
may include performance obligations, such as installation and integration services of our products to the customer’s network
and operating system. In multiple element arrangements that include the performance of services, product sales are recognized when
no significant performance obligations remain. In instances whereby the services provided in a multiple element arrangement are
considered essential to the functionality of the product and payment of the product is contingent upon performance of the services,
the sales of the products and services would be considered one unit of accounting.

The Company has attached in Annex A revised
disclosure that it proposes to include in its revenue recognition policy note for its next Form 20-F filing for the 2012 fiscal
year. The text is marked against the most recent Form 20-F.

5.	Your disclosure regarding multiple-element arrangements
addresses determination of selling price for maintenance and support, but it does not clearly address determination of selling
price for product sales or other services such as installation and training. Please tell us what consideration was given to providing
a discussion of the significant factors, inputs, assumptions, and methods used to determine selling price (whether vendor-specific
objective evidence, third-party evidence, or estimated selling price) for all significant deliverables. Please refer to ASC 605-25-50-2.

Response:

The selling price for products was determined
based on the estimated selling price, since neither VSOE or TPE was available. The estimated selling price was determined by reviewing
historical transactions and considering other multiple factors, including historical and anticipated margins on product; the selling
price and gross profit margin for similar products; geographies and market trends; and the Company’s existing pricing policies.

The selling price for maintenance and support
services was determined based on the estimated selling price by reviewing historical transactions and considering other multiple
factors, including the selling price for similar products; geographies and market trends; and the Company’s existing pricing
policies.

The Company’s significant deliverables
are products and maintenance and support services. At times, the Company provides professional services, such as installation services
and training. The estimated selling price for professional services and training was determined based on fixed daily billing rates
that are consistent with historical transactions and current pricing policies for the sale of such elements. Installation and training
services comprise an insignificant portion of a customer order and represented less than 3% of the Company’s revenues for
the year ended December 31, 2011. Accordingly, these elements were not deemed to be significant deliverables that require additional
disclosure as referred to in ASC 605-25-50-2.

    5

        Securities and Exchange
        Commission

    December 28, 2012

The Company has attached in Annex A revised
disclosure that it proposes to include in its revenue recognition policy note for its next Form 20-F filing for the 2012 fiscal
year in order to further clarify its determination of the estimated selling price for its products. The text is marked against
the disclosure in the most recent Form 20-F.

6.	While your disclosure addresses the basic revenue recognition
criteria related to product sales, it is not clear when delivery typically occurs and when the related revenues are typically recognized.
We note your disclosure on page 8 that “revenues from individual customers may fluctuate from time to time based on the timing
and the terms under which further orders are received and the duration of the delivery and implementation of such orders.”
Please tell us what consideration was given to disclosing the general timing of delivery or performance of service and the general
timing of revenue recognition for product sales. Please refer to ASC 605-25-50-2.

Response:

All of the Company’s multiple-element
arrangements consist of the sale of the product and maintenance and support services. At times, the Company’s arrangements
may also include professional services, such as installation services or training.

Delivery of the Company’s products
occurs upon transfer of title and risk of loss to the customer. In multiple element arrangements, revenues from products will be
deferred in instances where product payment is contingent upon performance of installation or other service obligations. In instances
where final acceptance of the product or service is specified by the customer, revenue is deferred until all acceptance criteria
is met.

Maintenance and support service for the
product is recognized ratably