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United States securities and exchange commission logo
October 19, 2020
Ziv Leitman
Chief Financial 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, 2019
Filed March 26,
2020
File No. 001-33129
Dear Mr. Leitman:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise 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
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2019
Note 2. Significant Accounting Policies
l. Revenue recognition, page F-16
1. Your disclosures
indicate that certain arrangements with large service providers may
include complex
customization services. Please tell us the following as it relates to such
arrangements:
Describe the
nature of your customization services;
Clarify whether
such services are separate performance obligations and specifically
address how you
considered the guidance in ASC 606-10-25-21 in making such
determination;
Tell us when
revenue is recognized for arrangements that involve customization.
Ziv Leitman
Allot Ltd.
October 19, 2020
Page 2
Specifically address how you considered the guidance in
606-10-25-27 or explain
what guidance you applied to these arrangements; and
Tell us the amount of revenue recognized from arrangements that
involve
customization services for each period presented.
2. You state that sales commissions are amortized as expense over the
revenue recognition
period. Please clarify what you mean by revenue recognition period.
Also tell us whether
additional sales commissions are paid upon contract renewal and, if
so, whether such
amounts are commensurate with the initial commissions. Refer to ASC
340-40-35-1 and
50-2.
3. You disclose the amount of the transaction price allocated to
remaining performance
obligations that is expected to be recognized after the year ending
December 31, 2020.
Please also disclose the remaining performance obligations that are
expected to be
recognized prior to December 31, 2020 such that the combined
disclosures represent the
the aggregate amount of the transaction price allocated to all
performance obligations that
are unsatisfied or partially satisfied as of the end of the reporting.
Refer to ASC 606-10-
50-13.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Eiko Yaoita Pyles, Staff Accountant, at (202) 551-3587
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 with any questions.
FirstName LastNameZiv Leitman Sincerely,
Comapany NameAllot Ltd.
Division of
Corporation Finance
October 19, 2020 Page 2 Office of
Technology
FirstName LastName