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                             December 18, 2020

       Kurtis Joseph Binder
       Chief Financial Officer
       CalAmp Corp.
       15635 Alton Parkway
       Suite 250
       Irvine, CA 92618

                                                        Re: CalAmp Corp.
                                                            Form 10-K for the
Year Ended February 29, 2020
                                                            Filed May 6, 2020
                                                            Form 10-Q for the
Quarter Ended November 30, 2020
                                                            Filed December 17,
2020
                                                            File No. 000-12182

       Dear Mr. Binder:

              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 the Year Ended February 29, 2020

       Notes to Consolidated Financial Statements
       Note 10 - Financing Arrangements, page 77

   1.                                                   Please address the
following comments related to the issuance of your convertible senior
                                                        unsecured notes:

                                                              We note that you
amortize the debt discount and debt issuance costs associated with
                                                            the liability
component of the notes over their "term." Please tell us how your
                                                            amortization policy
complies with the guidance in ASC 470-20-35-13 requiring
                                                            amortization of
such items over the expected life of a similar liability that does not
                                                            have an associated
equity component.
 Kurtis Joseph Binder
FirstName  LastNameKurtis Joseph Binder
CalAmp Corp.
Comapany18,
December   NameCalAmp
               2020       Corp.
December
Page 2     18, 2020 Page 2
FirstName LastName

                You disclose on page 90 that it is your intent to settle the
principal amount of these
              notes with cash and, therefore, you use the treasury stock method
for diluted EPS
              purposes. Explain in sufficient detail how you determined it was
not appropriate to
              presume share settlement and apply the if-converted method and
how you determined
              use of the treasury stock method was appropriate. See ASC
260-10-45-45 through -
              47, ASC 260-10-45-40 through 41, and ASC 260-10-55-36A.
Form 10-Q for the Fiscal Quarter Ended November 30, 2020

Note 16 - Legal Proceedings, page 24

2.       We note that you have accrued your best estimate of the probable
liability with respect to
         the Omega patent infringement claim based on reasonable royalty rates
for similar
         technologies. To the extent it is reasonably possible you will incur
losses in excess of
         recorded accruals related to this and/or other contingencies, please
provide the applicable
         disclosures required by ASC 450-20-50-3 through 4, including the
amount or range of
         reasonably possible losses in excess of recorded amounts.
Alternatively, if no amount of
         loss in excess of recorded accruals is believed to be reasonably
possible, please state this
         in your disclosure.
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Operating Results, page 26

3.       Where you describe two or more business reasons that contributed to a
material change in
         a financial statement line item between periods, please quantify in
future filings, where
         possible, the extent to which each factor contributed to the overall
change in that line
         item. For example, please quantify the extent to which the change in
your Software
         & Subscription Services revenues were attributable to the government,
municipalities and
         K-12 school bus end markets, your international recovery services, and
your Mexican
         operations. As part of your response, please provide us with an
example of the disclosure
         to be included in future filings based on current results.
4.       We note your disclosures on page 27 that the changes in your gross
profit and gross profit
         margin for the quarter ended November 30, 2020 were due to "lower
revenue" and
         "continued growth." Please revise future filings to provide greater
insight regarding the
         factors contributing to changes in your gross profit and gross profit
margin. In doing so,
         separately discuss on a consolidated and segment basis the changes in
your cost of
         revenues on an absolute basis and as a percentage of sales. To the
extent that materially
         offsetting amounts do not result in a material period over period
changes on a net basis,
         please ensure you separately disclose, quantify, and discuss the
impacts on a gross
         basis. As part of your response, please provide us with examples of
your intended
         disclosures based on current financial results.
 Kurtis Joseph Binder
CalAmp Corp.
December 18, 2020
Page 3

       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 Effie Simpson at (202) 551-3346 or Andrew Blume at (202)
551-3254
with any questions.



                                                          Sincerely,
FirstName LastNameKurtis Joseph Binder
                                                          Division of
Corporation Finance
Comapany NameCalAmp Corp.
                                                          Office of
Manufacturing
December 18, 2020 Page 3
cc:       S. Moran, General Counsel
FirstName LastName