September 17, 2018

David Potts
Chief Financial Officer
ARRIS International plc
3871 Lakefield Drive
Suwanee, Georgia 30024

       Re: ARRIS International plc
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 1, 2018
           Form 10-Q for the Quarterly Period Ended June 30, 2018
           Filed August 8, 2018
           File No. 001-37672

Dear Mr. Potts:

        We have reviewed your filing and have the following comments. Please
comply with the
following comment in future filings. 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-Q for the Quarterly Period Ended June 30, 2018

Notes to the Financial Statements
Note 3. Revenue from Contracts with Customers, page 8

1.    We note your statement on page nine that "Installation, training, and
professional and
      support services are recognized as control of the services transfer to
the customer. This is
      either over time or at a point in time depending on the details of the
arrangement and the
      timing of when the customer can direct the use of and obtain
substantially all the
      remaining benefits from the services provided." In this regard, please
clarify which
      services are recognized over time and which services are recognized at a
point in time.
 David Potts
ARRIS International plc
September 17, 2018
Page 2
2.       We note your disclosure states that equipment deliverables typically
include proprietary
         operating system software, which is not considered separately
identifiable. Please tell us
         if your contracts with customers include an obligation to provide
updates to the software
         embedded in your hardware products. If so, please describe for us the
terms associated
         with your obligation to provide updates and tell us how you considered
the impact of this
         obligation on your allocation of transaction price and timing of
revenue recognition.
Note 5. Goodwill and Intangible Assets, page 14

3.       We note the statement on page 15 that you recorded impairment as a
"result of the indirect
         effect of a change in accounting principle related to the adoption of
new accounting
         standard Revenue from Contracts with Customers, resulting in changes
in the composition
         and carrying amount of the net assets of our Cloud TV reporting unit."
Please explain
         how the new revenue standard impacted the composition and carrying
amount of the net
         assets of your Cloud TV reporting unit. Refer to your basis in the
accounting literature.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Supplemental Information - Adjusted Direct Contribution and Other Costs, page
38

4.       It appears that adjusted direct contribution, for each segment and in
total, and total direct
         contribution are non-GAAP financial measures. Please revise in future
filings to include a
         reconciliation that begins with the most directly comparable GAAP
financial measure.
         We refer to guidance in Item 10(e)(1)(i) of Regulation S-K. Also
please refer to questions
         104.03 and 104.04 of the updated Compliance and Disclosure
Interpretation Guidance on
         non-GAAP measures.
        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 Inessa Kessman, Senior Staff Accountant at 202-551-3371
or Terry
French, Accounting Branch Chief at 292-551-3828 if you have questions regarding
comments on
the financial statements and related matters. Please contact Joshua Shainess,
Staff Attorney at
202-551-7951 or Kathleen Krebs, Special Counsel at 202-551-3350 with any other
questions.



FirstName LastNameDavid Potts                                  Sincerely,
Comapany NameARRIS International plc
                                                               Division of
Corporation Finance
September 17, 2018 Page 2                                      Office of
Telecommunications
FirstName LastName