July 12, 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 reviewed your June 24, 2024 response to our comment letter 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. Unless we
note otherwise, any references to prior comments are to comments in our June
17, 2024 letter.

Form 20-F for the Year Ended December 31, 2023
Form 6-K furnished May 7, 2024
Exhibit 99.1, page 8

1.     We note your response to prior comment 3. While we acknowledge your
initial non-
       GAAP adjustment related to the valuation allowance reversal, it is
unclear why you
       include adjustments in subsequent periods related to "the realization
of...Deferred Tax
       Assets." Please describe to us in further detail the nature of the
adjustment and how you
       specifically calculate the amounts. Also tell us if the adjustments
result in non-GAAP
       taxes commensurate with non-GAAP net income (loss). Please refer to the
guidance
       discussed in Question 100.04 of the Non-GAAP Financial Measures
Compliance and
       Disclosure Interpretations.
Liquidity and Capital Resources, page 63

2.     We note your proposed cash flow disclosures in response to prior comment
1 still largely
 July 12, 2024
Page 2

       appear to be a recitation of changes evident from the financial
statements. As previously
       requested, please explain in sufficient detail the underlying reasons
and implications of
       material changes between periods to provide investors with an
understanding of trends
       and variability in cash flows. Ensure your revised disclosures
materially satisfy the
       requirements of Item 303(a)-(b) of Regulation S-K and the three
principal objectives of
       MD&A, as noted in SEC Release No. 33-8350:

             to provide a narrative explanation of a company   s financial
statements that enables
           investors to see the company through the eyes of management;

             to enhance the overall financial disclosure and provide the
context within which
           financial information should be analyzed; and

             to provide information about the quality of, and potential
variability of, a company   s
           earnings and cash flow, so that investors can ascertain the
likelihood that past
           performance is indicative of future performance

       Please contact Heather Clark at 202-551-3624 or Andrew Blume at
202-551-3254 if you
have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing