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                               March 11, 2022

       Marcelo Fischer
       Chief Financial Officer
       IDT Corporation
       520 Broad Street
       Newark, NJ 07102

                                                        Re: IDT Corporation
                                                            Form 10-K for the
Year Ended July 31, 2021
                                                            Filed October 14,
2021
                                                            Form 8-K furnished
March 7, 2022
                                                            File No. 001-16371

       Dear Mr. Fischer:

              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 10-K for Fiscal Year Ended July 31, 2021

       Consolidated Statements of Cash Flows, page F-8

   1.                                                   We note you include the
change in Customer deposits at IDT Financial Services Limited
                                                        (Gibraltar-based bank)
within operating activities. Please tell us the specific guidance in
                                                        ASC 230 you relied upon
in your determination to classify the cash flows associated with
                                                        this liability as
operating activities. In your response, tell us about the nature and timing
                                                        of the underlying cash
flows and how you considered an alternative classification such as
                                                        financing activities.
In addition, reconcile for us the amount of the net change
                                                        in Customer deposits at
IDT Financial Services Limited (Gibraltar-based bank) as
                                                        disclosed on your cash
flow statement for fiscal 2021 to the net change in the customer
                                                        deposits liability
presented on your balance sheet.
 Marcelo Fischer
FirstName  LastNameMarcelo Fischer
IDT Corporation
Comapany
March      NameIDT Corporation
       11, 2022
March2 11, 2022 Page 2
Page
FirstName LastName
Note 5 - Cash, Cash Equivalents, and Restricted Cash and Cash Equivalents, page
F-8

2.       Please revise to describe the nature of the restrictions applicable to
restricted cash and
         cash equivalents. Refer to ASC 230-10-50-7 and Rule 5-02(1) of
Regulation S-X.
Form 8-K furnished March 7, 2022

Exhibit 99.1, page 1

3.       When disclosing Adjusted EBITDA, please revise to disclose the
corresponding GAAP
         measure with equal or greater prominence. In this regard we note that
you
         present Adjusted EBITDA in the highlighted bullet points but do not
disclose the
         comparable GAAP measure of net (loss) income attributable to IDT.
Similarly, you
         present Adjusted EBITDA prior to GAAP net (loss) income attributable
to IDT in the
         tabular presentation of Consolidated Results. Also, the starting point
for your
         reconciliations of Adjusted EBITDA should be the most directly
comparable GAAP
         measure, which you disclose is net (loss) income attributable to IDT
on a consolidated
         basis and income (loss) from operations for the reportable segments.
Please revise and in
         your response provide us with the disclosures you intend to include in
future filings. Refer
         to Item 10(e)(1)(i) of Regulation S-K and Question 102.10 of the
Non-GAAP C&DIs.
4.       Your measure of Adjusted EBITDA less CAPEX appears to be a non-GAAP
liquidity
         measure based upon your disclosure related to key performance metrics.
Please revise to
         identify this as a non-GAAP measure, present the most directly
comparable GAAP
         measure with equal or greater prominence, and provide a reconciliation
to the comparable
         GAAP measure, which appears to be net cash (used in) provided by
operating activities.
         In addition, refrain from implying that the non-GAAP measure is
equivalent to or
         a substitute for GAAP cash flow information. In this regard, we note
your disclosure that
         Adjusted EBITDA less CAPEX is a reasonable proxy for the cash
generated by IDT   s
         businesses. Refer to Question 102.07 of the non-GAAP C&DIs. Please
revise and in
         your response provide us with the disclosures you intend to include in
future filings.
5.       We note your reference to consolidated
revenue-less-direct-cost-of-revenue in the
         highlighted bullet points appears to present a non-GAAP measure of
gross profit.
         Similarly, your measure of revenue-less-direct-cost-of-revenue as a
percentage of revenue,
         which you identify as a key performance metric both here and in your
Form 10-K and
         Form 10-Q filings, appears to be a non-GAAP measure of gross profit
margin. Please
         revise to identify both of these as non-GAAP measures, provide the
comparable GAAP
         measure of gross profit, including amortization and depreciation and
GAAP gross
         profit, including amortization and depreciation, as a percentage of
revenue with equal or
         greater prominence. Also, revise to explain how you use these measures
and why you
         believe they are useful to investors. Refer to SAB Topic 11.B. In your
response provide
         us with the disclosures you intend to include in future filings.
 Marcelo Fischer
FirstName  LastNameMarcelo Fischer
IDT Corporation
Comapany
March      NameIDT Corporation
       11, 2022
March3 11, 2022 Page 3
Page
FirstName LastName
       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 Joyce Sweeney, Senior Staff Accountant, at (202)
551-3449 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 with any
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology