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                            June 17, 2024

       Niran Baruch
       Chief Financial Officer
       AUDIOCODES LTD
       1 Hayarden Steet
       Airport City Lod 7019900, Israel

                                                        Re: AUDIOCODES LTD
                                                            Form 20-F for the
Year Ended December 31, 2023
                                                            Form 6-K furnished
May 7, 2024
                                                            File No. 000-30070

       Dear Niran Baruch:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment(s).

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 20-F for the Year Ended December 31, 2023

       Liquidity and Capital Resources, page 63

   1.                                                   Please provide a more
informative discussion and analysis of cash flows from operating,
                                                        investing and financing
activities, including changes in working capital components, for
                                                        the periods presented.
In doing so, explain the underlying reasons and implications of
                                                        material changes
between periods to provide investors with an understanding of trends
                                                        and variability in cash
flows. Ensure that your disclosures are not merely a recitation of
                                                        changes evident from
the financial statements. Refer to Item 303(a) of Regulation S-K and
                                                        SEC Release No.
33-8350.
 Niran Baruch
AUDIOCODES LTD
June 17, 2024
Page 2
Financial Statements
Notes to Consolidated Financial Statements
Note 2:- Significant Accounting Policies
i. Inventories, page F-14

2.       You disclose that inventories are stated at the lower of cost or
market. Please clarify if you
         recognize inventory at the lower of cost or market, or the lower of
cost or net realizable
         value, and revise your disclosures accordingly. See ASC 330-10-35-1B.
Form 6-K furnished May 7, 2024

Exhibit 99.1, page 8

3.       We note your non-GAAP adjustments for "Lease expense" and "Deferred
         tax." Considering these expenses appear to represent normal and
recurring operating
         expenses necessary to run your business, please tell us how you
determined these
         adjustments were appropriate. If you believe these adjustments are in
compliance with
         non-GAAP rules, please advise. Also tell us if your non-GAAP
adjustments are presented
         on a net of tax basis. If so, revise to present the adjustments on a
pre-tax basis with the
         income tax impact shown as a separate adjustment and clear disclosure
of how the tax
         impact was calculated. Refer to Questions 100.01 and 102.11 of the
Non-GAAP Financial
         Measures Compliance and Disclosure Interpretations.

       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.

       Please contact Heather Clark at 202-551-3624 or Andrew Blume at
202-551-3254 with
any questions.



FirstName LastNameNiran Baruch                                  Sincerely,
Comapany NameAUDIOCODES LTD
                                                                Division of
Corporation Finance
June 17, 2024 Page 2                                            Office of
Manufacturing
FirstName LastName