SEC Company Response from Allot Ltd. (ALLT) (CIK 0001365767) (ALLT) — Jan 11, 2010
Allot Ltd. (ALLT) (CIK 0001365767)
Date: Jan. 11, 2010 · CIK: 0001365767 · Accession: 0001178913-10-000098
AI Filing Summary & Sentiment
File numbers found in text: 001-33129
Referenced dates: January 6, 2010
Letter
Securities and Exchange Commission Division of Corporation Finance 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 January 6, 2010 (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.
As previously requested, provide a 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.
Securities and Exchange Commission
January 11,
Response:
The Company has provided the required statement concurrently herewith.
2.
Please refer to prior comment 5. We not that you requested confidential treatment pursuant to Rule 83 of the Freedom of Information Act for information contained in the separately provided letter referenced in your response. Please note that Rule 83 sets forth the procedures for a registrant to request confidential treatment for information contained in a response letter or for supplemental information provided to us. If you seek to rely upon this rule, the response letter submitted electronically must, on each page where you omit information from the electronic version of the letter, designate or mark the place where you omit material and tie the omission to a legend that indicates material has been omitted and provide any other required information. Note that the rule also requires you to clearly mark each page with the words “Confidential Treatment Requested by [name]” and an identifying number and code, such as a Bates-stamped number. Further, in your written request for confidential treatment, you must refer to the record by the identifying number and code. If you wish to rely on this rule, please re-file your correspondence on EDGAR accordingly and resubmit a confidential treatment request that conform to the rule.
Response:
The Company has resubmitted its initial response letter and request for confidential treatment in response to this comment.
* * *
Please do not hesitate to contact Colin Diamond at (212) 819-8754 of White & Case LLP with any questions or comments regarding this letter.
Sincerely,
/s/ White & Case
LLP
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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
January
11, 2010
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 January 6, 2010 (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.
As
previously requested, provide a 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.
Securities
and Exchange Commission
January 11,
2010
Response:
The
Company has provided the required statement concurrently herewith.
2.
Please
refer to prior comment 5. We not that you requested
confidential treatment pursuant to Rule 83 of the Freedom of Information
Act for information contained in the separately provided letter referenced
in your response. Please note that Rule 83 sets forth the
procedures for a registrant to request confidential treatment for
information contained in a response letter or for supplemental information
provided to us. If you seek to rely upon this rule, the
response letter submitted electronically must, on each page where you omit
information from the electronic version of the letter, designate or mark
the place where you omit material and tie the omission to a legend that
indicates material has been omitted and provide any other required
information. Note that the rule also requires you to clearly
mark each page with the words “Confidential Treatment Requested by [name]”
and an identifying number and code, such as a Bates-stamped
number. Further, in your written request for confidential
treatment, you must refer to the record by the identifying number and
code. If you wish to rely on this rule, please re-file your
correspondence on EDGAR accordingly and resubmit a confidential treatment
request that conform to the rule.
Response:
The
Company has resubmitted its initial response letter and request for confidential
treatment in response to this comment.
* * *
Please do
not hesitate to contact Colin Diamond at (212) 819-8754 of White & Case LLP
with any questions or comments regarding this letter.
Sincerely,
/s/ White & Case
LLP
White
& Case LLP
cc:
Mr.
Rami Hadar
Mr.
Doron Arazi
2