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            White
      & Case LLP

              1155 Avenue of the Americas

              New York, New York 10036-2787

            Tel  +1 212 819
      8200

              Fax  +1 212 354 8113

              www.whitecase.com

FOIA Confidential Treatment
Request

      Pursuant to Rule 83 by Allot
Communications Ltd.

      December
18, 2009

      Securities
and Exchange Commission

      Division
of Corporation Finance

      100 F
Street, N.E.

      Washington,
D.C. 20549

                  Attn:

                  Mr.
      Patrick Gilmore

                  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.
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 November 25, 2009 (the
“Comment
Letter”) with respect to the above-referenced filing 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.

                1.

                You
      state that certain hardware components that are used in your products are
      obtained from single or limited sources.  Please tell us how you
      determined that the limited source supplier agreement with the companies
      you cite in this risk factor need not be filed as exhibits pursuant to
      Instruction 4(b)(ii) to the
Exhibits.

          12-18-09-01

                  Securities
      and Exchange Commission

                  FOIA
      Confidential Treatment Request

        Pursuant to Rule 83 by Allot
Communications Ltd.

        December
18, 2009

        FOIA Confidential Treatment
Request

        Pursuant to Rule 83 by Allot
Communications Ltd.

      Response:

      The risk
factor referenced the following products and related suppliers:

                Product

                Component

                Supplier

                NetEnforcer
      AC-400

                NetEnforcer
      AC-800

                Central
      processing unit

                Intel
      Corporation

                NetEnforcer
      AC-1000

                NetEnforcer
      AC-2500

                Network
      processor

                Hifn,
      Inc.

                NetEnforcer-10000

                Service
      Gateway platforms

                Central
      processing unit

                Raza
      Microelectronics, Inc.

      The
Company does not believe that its agreements or other purchasing arrangements
with the above-referenced suppliers were required to be filed based on the
following reasoning:

      Instruction
4(b)(ii) refers to “continuing contracts…to purchase the major part of your
requirement of goods, services or raw materials.”  The preamble to
that subsection states that “Even if a contract falls into one of these
categories, you do not have to file the contract if it is immaterial in amount
or significance.”

      The
Company does not have a supply agreement with Intel and, accordingly, could not
file any agreement as an exhibit.  The Company’s agreements with Hifn
and Raza do not require any minimum purchases nor commit those companies to make
any minimum amount available for purchase.  Each agreement merely
provides that the Company may submit purchase orders and sets forth the terms of
licenses for software included in any products supplied.  As such,
they do not contain any terms that would be material to
investors.  This is one reason that the Company believes these
contracts are immaterial in significance.

      The other
reason that the Company believes the contracts are immaterial in significance is
that each of the components supplied is an off-the-shelf item, none of which
were designed or manufactured specifically for the Company.  As a
result, these components may be purchased by other customers in addition to the
Company.  Suppliers of such components generally announce end of life
policies and the Company can increase its inventory accordingly to allow enough
time to modify products to accommodate alternate components.  The
Company has disclosed this fact, and its related practices, clearly on page 29
of the Form 20-F:

          12-18-09-02

                    Securities
      and Exchange Commission

                    FOIA
      Confidential Treatment Request

          Pursuant to Rule 83 by Allot
Communications Ltd.

          December
18, 2009

          FOIA Confidential Treatment
Request

          Pursuant to Rule 83 by Allot
Communications Ltd.

      “We carry
approximately three to six months of inventory of key components. We also work
closely with our suppliers to monitor the end-of-life of the product cycle for
integral components, and believe that in the event that they announce end of
life, we will be able to increase our inventory to allow enough time for
replacing the products. We have been informed by Hifn that it is their general
policy to provide their customers with a six-month last-time-buy option and
twelve months to take delivery of the product in the event that Hifn decides to
discontinue production of the network processor.”

      The
Company provided the above disclosure with respect to its inventory precisely
because it does not have any long-term supply agreements.  The Company
believes that its inventory practices outlined above, and the nature of its
agreements with Hifn and Raza, mean that the Company is not substantially
dependent on any agreement or purchasing arrangement.  In addition to
the foregoing disclosure, the Company will clarify in future Form 20-Fs that it
does not have agreements that contain supply commitments.

                2.

                We
      note that your certifying officers concluded that you “have in place
      effective controls and procedures…”  Please refer to Item 15T(a)
      of Form 20-F and confirm, if true, that your “disclosure controls and
      procedures” were effective during the relevant period and confirm that you
      will provide conforming disclosure in future
  filings.

      Response:

      The
Company confirms that its certifying officers have concluded that its disclosure
controls and procedures were effective as of the end of the period covered by
the Form 20-F filed by the Company on May 7, 2009.  The Company will
provide conforming disclosure in future filings.

                3.

                You
      state that your Chief Executive Officer and Chief Financial Officer
      concluded that you “have in place effective controls and procedures
      designed to ensure that information disclosed by [you] in the reports
      [you] file or submit under the Exchange Act and the rules thereunder, is
      recorded, processed, summarized and reported within the time periods
      specified in the SEC’s rules and forms.”  This effectiveness
      conclusion is stated in terms that are more limited in scope than the
      definition of “disclosure controls and procedures” as set forth in
      Exchange Act Rule 13a-15(e).  In your response letter, please
      confirm, if true, that your disclosure controls and procedures were also
      effective to ensure that information required to be disclosed in the
      reports that you file or submit under the Exchange Act is accumulated and
      communicated to your management, including your Chief Executive Officer
      and Chief Financial Officer, as appropriate to allow timely decisions
      regarding required disclosures.  In future filings, to the
      extent you include a definition of disclosure controls and procedures in
      your effectiveness conclusion, please include the entire definition as set
      forth in Exchange Act Rule
13a-15(e).

          12-18-09-03

                    Securities
      and Exchange Commission

                    FOIA
      Confidential Treatment Request

          Pursuant to Rule 83 by Allot
Communications Ltd.

          December
18, 2009

          FOIA Confidential Treatment
Request

          Pursuant to Rule 83 by Allot
Communications Ltd.

      Response:

      The
Company confirms that its disclosure controls and procedures were effective to
ensure that information required to be disclosed in the reports that it files or
submits under the Exchange Act is accumulated and communicated to its
management, including its Chief Executive Officer and Chief Financial Officer,
as appropriate to allow timely decisions regarding required
disclosures.

      The
Company acknowledges the Staff’s comment and, to the extent a definition of
“disclosure controls and procedures” is included in its effectiveness
conclusion, will include the entire definition as set forth in Exchange Act Rule
13a-15(e) in future filings.

                4.

                While
      you state that no “material changes” in your internal control over
      financial reporting occurred during the fiscal year ended 2008 that
      materially affected your internal control over financial reporting, please
      note that Item 15T(c) requires disclosure of “any change” in your internal
      control over financial reporting that has materially affected or is
      reasonably likely to materially affect, your internal control over
      financial reporting.  Please confirm that there were no changes
      in your internal control over financial reporting that materially
      affected, or were reasonably likely to materially affect your internal
      control over financial reporting and provide us with a representation that
      you will provide conforming disclosure in future
  filings.

      Response:

      The
Company confirms that there were no changes in its internal control over
financial reporting that materially affected, or were reasonably likely to
materially affect, its internal control over financial reporting.  The
Company will provide conforming disclosure in future filings.

          12-18-09-04

                    Securities
      and Exchange Commission

                    FOIA
      Confidential Treatment Request

          Pursuant to Rule 83 by Allot
Communications Ltd.

          December
18, 2009

          FOIA Confidential Treatment
Request

          Pursuant to Rule 83 by Allot
Communications Ltd.

                5.

                We
      note your disclosure that vendor-specific objective evidence (“VSOE”) of
      your maintenance and support services is based on the “price when sold
      separately.”  Please describe, in detail, your methodology for
      establishing VSOE.  If VSOE is based on stated renewal rates
      then please tell us how you determined the renewal rates are
      substantive.  In this regard, please provide the range of
      renewal rates and tell us what percentage of your customers actually renew
      at such rates.  Alternately, if VSOE is based on stand-alone
      sales, then provide the volume and range of stand alone sales used to
      establish VSOE.  Also, please describe the various factors that
      affect your VSOE analysis including customer type and other pricing
      factors (e.g., geographic region, purchase volume, competitive pricing,
      perpetual versus term license,
etc.).

      Response:

      As of
December 31, 2008, the Company offered two maintenance and support plans. The
basic support plan includes hardware advance replacement, software bug fixing,
unspecified updates and upgrades (on a when-and-if-available basis) and
technical support services. The second plan is an extended support plan that
includes on site support in addition to the services provided under the basic
support plan.

      The
Company’s process for establishing VSOE of fair value of the basic support plan
is through the performance of a VSOE compliance test which is an analysis of the
basic support plan annual renewal activity for the installed base of the
Company. VSOE of fair value of the basic support plan is based on the actual
renewal price, calculated as a percentage of the respective price list (“Renewal
Rate”).

      The
Company used the Bell Shaped Curve approach to establish its VSOE of fair value
of the basic support plan in accordance with the provision of paragraph 10 of
SOP 97-2. VSOE of fair value of the basic support plan exists when a substantial
majority of the Company’s actual basic support plan renewals are within a narrow
range of plus or minus 20% of the midpoint of the Renewal Rates. The compliance
test was conducted using two variables: geographic region and type of
customer.

      The table
below summarizes the results of the abovementioned analysis:

                Region

                Customer
      Type

                Number
      of Renewals

                Percentage
      of Renewals Falling Within the Range

                ROW

                Distributor

                648

                74%

                Reseller

                114

                79%

                End
      User

                29

                76%

                America

                Distributor

                319

                92%

                Reseller

                143

                93%

                End
      User

                46

                85%

          12-18-09-05

                    Securities
      and Exchange Commission

                    FOIA
      Confidential Treatment Request

          Pursuant to Rule 83 by Allot
Communications Ltd.

          December
18, 2009

          FOIA Confidential Treatment
Request

          Pursuant to Rule 83 by Allot
Communications Ltd.

      The
Company’s process for establishing VSOE of fair value of the extended support
plan is through the performance of a VSOE compliance test for the renewal rates
stated in customers’ contracts.  This process, known as the
Substantive Renewal Rate approach, was conducted in accordance with the
provision of paragraph 10 of SOP 97-2. VSOE of fair value of the extended
support plan is based on the renewal rate as permitted by AICPA Technical
Practice Aid 5100.55, “Fair Value of PCS with a Consistent Renewal Percentage
(But Varying Renewal Dollar Amounts) and Software Revenue
Recognition.”

      The
Company determined that the renewal rates applicable for the extended support
plan were substantive based on their actual rate of <***>%.

      The
stated renewal rates for the extended support plan were all within a narrow
range of plus or minus 15% of their respective midpoint. The original terms of
the contracts with stated renewal rates have not yet expired. In addition, this
extended support plan was also sold separately for a price reflecting a rate
within the same narrow range of the stated renewal rates mentioned
above.  In that case, the original contract included only the basic
support plan and the renewal rate for the extended support plan was agreed
separately when the service was renewed and extended.

                6.

                We note several references
      throughout your Form 20-F to third party valuations.  For
      example, on page F-20 you indicate that the fair value of intangible
      assets acquired was based on third-party valuation.  Also, on
      page F-21 you indicate that a third party valuation was used to determine
      the fair value of certain auction rate securities.  For each
      reference to a third party valuation in your Form 20-F please describe for