August 1, 2005



Via EDGAR

Mr. Craig Wilson
Securities and Exchange Commission
Division of Corporation Finance
100 F Street N. E.
Washington, D.C. 20549

     RE:  CONCURRENT COMPUTER CORPORATION
          FORM 10-K FOR THE FISCAL YEAR ENDED JUNE 30, 2004,
          FILED SEPTEMBER 7, 2004 (FILE NO. 000-13150)

Dear Mr. Wilson:

     This letter sets forth the responses of Concurrent Computer Corporation
(the "Company") to the comments of the staff (the "Staff") of the Securities and
Exchange Commission (the "Commission") with regard to the Form 10-K for the
fiscal year ended June 30, 2004.  The Staff's comments were provided to the
Company in a letter dated June 16, 2005.

     In connection with responding to these comments, the Company acknowledges
that:

          -    the Company is responsible for the adequacy and accuracy of the
               disclosure in the filing;

          -    Staff comments or changes to disclosures in response to Staff
               comments do not foreclose the Commission from taking any action
               with respect to the filing; and

          -    the Company may not assert Staff comments as a defense in any
               proceeding initiated by the Commission or any person under the
               federal securities laws of the United States.


Revenue Recognition and Related Matters, page 52
- ------------------------------------------------

1.   We note from disclosures within the filing that your customers include
     government agencies. Considering this, tell us how you considered
     paragraphs 32 - 33 of SOP 97-2



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Page 2

     in accounting for fiscal funding clauses, if any, included in your software
     arrangements. Also tell us how fiscal funding clauses or other government
     contract contingencies impact your revenue recognition for other services
     and products you provide.

     Response: The Company's sales to governmental agencies relate entirely to
     sales of its high-performance ("real-time") products. Government related
     sales are primarily related to sales to government prime contractors,
     rather than directly to governmental agencies. The contracts with the
     government prime contractors do not contain fiscal funding clauses or other
     contingencies. In fiscal 2004, the Company recorded $14.2 million in
     revenues to U.S. government prime contractors and agencies of the U.S.
     government. Approximately $2.0 million of this amount related directly to
     U.S. governmental agencies. This revenue to U.S. governmental agencies was
     primarily related to maintenance fees that are renewed on an annual basis.
     Some of these annual maintenance contracts do include fiscal funding
     clauses. In accordance with paragraphs 32 and 33 of SOP 97-2, "Software
     Revenue Recognition" ("SOP 97-2"), the Company has determined that the
     fiscal funding clauses are contingencies that raise a question as to
     whether a fee is fixed or determinable or if collectibility is reasonably
     assured. As a result, the Company defers recognizing revenue until the
     Company receives notification that funding has been approved and that funds
     have been released.

     Additionally, with regard to any past or future real-time product sales
     directly to U.S. governmental agencies, the Company defers recognizing
     revenue until the funding has been approved and the funds have been
     released.


2.   Your revenue recognition policy does not appear to address all the revenue
     streams of your Company which appear to include, but are not limited to,
     long-term contracts involving customization, license fees, hardware,
     software maintenance, hardware maintenance, other software sales and video
     streams purchased. For example you disclose that you recognize revenue
     pursuant to SOP 97-2 and SOP 98-9 but it is not evident from this
     disclosure whether you recognize revenue for hardware, hardware
     maintenance, other software sales and video streams "purchased" pursuant to
     these standards. Tell us how you recognize revenue for each of your revenue
     streams, the authoritative literature that applies, how you determine the
     fair value of each element in multiple element arrangements and whether
     software is integral to the functionality of hardware you sell. In your
     response specifically address your consideration of EITF 00-21, FTB 90-1
     and EITF 03-5 as they relate to your revenue recognition policy for
     products and services.

     Response: The Company provides computer and software systems for both the
     on-demand market and the real-time market. The on-demand systems enable
     cable systems that have two way capability to deliver movies and a large
     variety of other content to subscribers with digital set-top boxes. The
     real-time systems and software are specially designed to acquire, process,
     store, analyze and display large amounts of rapidly changing information in
     real-time. The Company's standard contractual arrangements



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     with its customers generally include the delivery of a hardware and
     software system, certain professional services that typically involve
     installation and training, and ongoing software and hardware maintenance.

     The software component of the arrangement is considered to be essential to
     the functionality of the hardware. This determination is based on the fact
     that the Company modifies the hardware received from the hardware vendor in
     order for the hardware to function correctly with the software component.
     Additionally, the standard hardware received from the hardware vendor will
     not function to the customer's specifications without the software
     component or the modifications made by the Company prior to shipment.
     Therefore, in accordance with EITF No. 03-5, "Applicability of AICPA
     Statement of Position 97-2 to Non-Software Deliverables in an Arrangement
     Containing More-Than-Incidental Software", the hardware and the hardware
     maintenance components are considered software-related and the provisions
     of SOP 97-2 apply to the sale of the hardware.

     Consistent with the guidance in paragraph 4 a (i) of EITF 00-21, "Revenue
     Arrangements with Multiple Deliverables" ("EITF 00-21"), the Company has
     determined that EITF 00-21 does not apply to the customer arrangements as a
     higher level of generally accepted accounting principles, SOP 97-2, applies
     to all elements of the arrangement.

     The Company does use the term "price per stream" in its Form 10-K. For its
     on-demand product, the Company sometimes prices the hardware and software
     sold to customers based on a price per stream basis. The number of streams
     a system will process is an indication of volume or capacity of the system.
     This is, however, only used as a pricing mechanism for the hardware and
     software in some situations. The Company does not receive any additional
     "per stream" fees based on volume used by customers.

     The Company separates the elements of the customer arrangement based on the
     principles embedded in SOP 97-2. The Company bifurcates the undelivered
     elements related to professional services and hardware and software
     maintenance based on vendor specific objective evidence ("VSOE") and
     recognizes the revenue from the hardware and software elements based on the
     residual method as more fully discussed below.

     Software and Hardware Sales
     ---------------------------

     In most cases these products include both hardware and software. Revenue
     from hardware and software arrangements is recognized in accordance with
     the guidance in SOP 97-2 and SOP 98-9, "Modification of SOP 97-2, Software
     Revenue Recognition, with Respect to Certain Transactions." Revenue from
     hardware and software sales is generally recognized after the software has
     been installed on the hardware and the hardware has been shipped to the
     customer's site or upon receipt by the customer, depending on the shipping
     terms. Revenue is also only recognized if there are no significant
     obligations remaining and collection of the related receivable is probable.
     The Company's VSOE of fair value is determined based on the price charged
     when the



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     same element is sold separately. If VSOE of fair value does not exist for
     all elements in a multiple element arrangement, the Company recognizes
     revenue using the residual method. Under the residual method, the fair
     value of the undelivered elements is deferred and the remaining portion of
     the arrangement is recognized as revenue. Therefore, the revenue associated
     with the undelivered maintenance and professional services, if any, is
     deferred until the services are performed as discussed more fully below.

     Professional Services
     ---------------------

     The Company's professional services revenue is primarily generated from
     integration of third party software interfaces, training, and hardware
     installation. These services are typically completed within 90 days from
     the receipt of the order. Generally, as noted above, the hardware and
     software products are recognized as revenue upon delivery, based on the
     shipping terms. Additional service elements are recognized as revenue as
     those services are rendered. In accordance with SOP 97-2, the Company has
     determined that these service elements are to be accounted for separately
     as these services are not essential to the functionality of the software.
     This is evidenced by the fact that the hardware and software is not subject
     to return if the services are not performed. Other factors that indicate
     that these services qualify for accounting as a service element are that,
     in some cases, the services may be available from other vendors, the
     services do not carry a significant degree of risk or unique acceptance
     criteria, and the Company is an experienced provider of the services. The
     Company determines VSOE of fair value on the services based on the standard
     rate per hour or fixed fee used when similar services are sold separately.

     In limited situations, the Company has determined that the services that
     will be performed are essential to the functionality of the software
     primarily due to the customization requests of the individual client. When
     the Company determines that the professional services that are being
     performed do not qualify as a separate element of the arrangement under SOP
     97-2, because they do not meet the criteria noted above, the Company
     applies the provisions of SOP 81-1, "Accounting for Performance of
     Construction-Type and Certain Production-Type Contracts" ("SOP 81-1"), and
     records the value of the entire arrangement, excluding maintenance, as the
     project progresses based on actual costs incurred compared to the total
     costs expected to be incurred through completion. To date, the Company has
     had very few contracts accounted for under SOP 81-1.

     Hardware and Software Maintenance
     ---------------------------------

     In some cases the Company will include a "free" warranty period for
     hardware and software maintenance in the sales price. This warranty period
     can be for up to three years. In accordance with SOP 97-2 and, depending
     upon the specific terms of the customer agreement, the Company either
     accrues the estimated costs to be incurred in performing maintenance
     services at the time of revenue recognition and shipment of product, or the
     Company defers revenue associated with the maintenance services to be



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Page 5

     provided during the warranty period based upon the value for which the
     Company has sold such services separately when they are renewed by existing
     customers.

     For those arrangements in which the warranty period is less than or equal
     to one year, the Company, in accordance with meeting the criteria in
     paragraph 59 of SOP 97-2, accrues the estimated costs to be incurred in
     providing such services. In accordance with paragraph 59 of SOP 97-2, the
     Company has determined that the warranty fee is part of the initial license
     fee, the warranty period is for one year or less, the estimated cost of
     providing the services are immaterial, and the customer is not granted the
     rights to any upgrades and enhancements as defined in SOP 97-2. During the
     warranty period, the Company provides for the repair or replacement of
     defective equipment, provides telephone support, and provides software
     patches/bug fixes. Therefore, in accordance with AICPA Technical Practice
     Aid 43, "Corrections of Errors in Computer Software (Bug Fixes)", the
     Company accrues for those costs under SFAS No. 5, "Accounting for
     Contingencies". Actual costs are then charged against the warranty accrual
     as they are incurred.

     For those arrangements in which the warranty period is greater than one
     year, the Company defers revenue based upon the value for which the Company
     has sold such services separately. These services are available to
     customers through annual renewal contracts at the end of the warranty
     period. As such, the Company has determined that the maintenance is a
     separate element of the arrangement under SOP 97-2 and therefore, is
     recognized as revenue on a straight line basis over the warranty period.

     In some cases the Company does not include a "free" warranty period for
     hardware and software maintenance in the sales price and the customer will
     typically purchase a maintenance contract. Typically the customer will pay
     for the annual maintenance contract in advance. The Company determines VSOE
     of fair value for these services based on renewal rates charged when the
     service is sold separately. In these cases the Company will recognize the
     revenue on a straight line basis over the warranty period as this most
     closely estimates the earnings process of the services.


3.   Your disclosure for multiple elements does not appear to fully comply with
     the SAB 104, Topic 13.B Question 1, in regards to clearly stating the
     accounting policy for each unit of accounting as well as how units of
     accounting are determined and valued. Tell us how you plan to more fully
     comply with this guidance.

     Response: The Company will revise its future filings to include the
     following disclosure with regards to its revenue recognition policy:

     Revenue Recognition Policy
     --------------------------



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     The Company recognizes revenue when persuasive evidence of an arrangement
     exists, the system has been shipped, the fee is fixed or determinable and
     collectibility of the fee is probable.

     Software and Hardware Sales
     ---------------------------

     On-demand (formerly "VOD") and real-time (formerly "Integrated Solutions")
     product revenues are recognized based on the guidance in American Institute
     of Certified Public Accountants Statement of Position ("SOP") 97-2,
     "Software Revenue Recognition" ("SOP 97-2") and related amendments, SOP
     98-4, "Deferral of the Effective Date of a Provision of SOP 97-2, Software
     Revenue Recognition", and SOP 98-9, "Modification of SOP 97-2, Software
     Revenue Recognition, With Respect to Certain Transactions". The Company's
     standard contractual arrangements with its customers generally include the
     delivery of a hardware and software system, certain professional services
     that typically involve installation and training, and ongoing software and
     hardware maintenance. The software component of the arrangement is
     considered to be essential to the functionality of the hardware. Therefore,
     in accordance with Emerging Issues Task Force No. 03-5, "Applicability of
     AICPA Statement of Position 97-2 to Non-Software Deliverables in an
     Arrangement Containing More-Than-Incidental Software", the hardware and the
     hardware maintenance components are considered software related and the
     provisions of SOP 97-2 apply to all elements of the arrangement. Under
     multiple element arrangements, the Company allocates revenue to the various
     elements based on vendor-specific objective evidence ("VSOE") of fair
     value. The Company's VSOE of fair value is determined based on the price
     charged when the same element is sold separately. If VSOE of fair value
     does not exist for all elements in a multiple element arrangement, the
     Company recognizes revenue using the residual method. Under the residual
     method, the fair value of the undelivered elements is deferred and the
     remaining portion of the arrangement is recognized as revenue.

     Professional Services
     ---------------------

     Professional services revenue is primarily generated from integration of
     third party software interfaces, training, and hardware installation. These
     services are typically completed within 90 days from the receipt of the
     order. Under multiple element arrangements, the Company allocates revenue
     to the various elements based on VSOE of fair value. The Company determines
     VSOE of fair value for the services based on the standard rate per hour or
     fixed fee used when similar services are sold separately. Revenues from
     these services are recognized when the services are performed.

     In certain instances, the Company's customers require significant
     customization of both the software and hardware products. In these
     situations, the services are considered essential to the functionality of
     the software and, therefore, the revenue from the arrangement, with the
     exception of maintenance, is recognized in conformity with Accounting
     Research Bulletin ("ARB") No. 45, "Long Term Construction Type Contracts"
     and SOP 81-1, "Accounting for Performance of Construction-Type and



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     Certain Production-Type Contracts." The Company records the value of the
     entire arrangement (excluding maintenance) as the project progresses based
     on actual costs incurred compared to the total costs expected to be
     incurred through completion.

     Hardware and Software Maintenance
     ---------------------------------

     The Company recognizes revenue from maintenance services in accordance with
     SOP 97-2. Depending upon the specific terms of the customer agreement, the
     Company may include warranty as part of the purchase price. In accordance
     with SOP 97-2 and, depending upon the specific terms of the customer
     agreement, the Company either accrues the estimated costs to be incurred in
     performing maintenance services at the time of revenue recognition and
     shipment of product, or the Company defers revenue associated with the
     maintenance services to be provided during the warranty period based upon
     the value for which the Company has sold such services separately when they
     are renewed by existing customers. For those arrangements in which the
     warranty period is less than or equal to one year, the Company accrues the
     estimated costs to be incurred in providing services. In accordance with
     paragraph 59 of SOP 97-2, the Company has determined that the warranty fee
     is part of the initial license fee, the warranty period is for one year or
     less, the estimated cost of providing the services are immaterial, and
     upgrades and enhancements offered during maintenance arrangements
     historically have been and are expected to continue to be minimal and
     infrequent. Actual costs are then charged against the warranty accrual as
     they are incurred. For those arrangements in which the warranty period is
     greater than one year, the Company defers revenue based upon the value for
     which the Company has sold such services separately. This revenue is then
     recognized on a straight line basis over the warranty period.



     Please contact the undersigned at (678) 258-4052 with any questions
concerning this letter.


                              Sincerely,

                              /s/Greg Wilson

                              Greg Wilson
                              Chief Financial Officer

cc:  Ms. Megan Akst - Securities and Exchange Commission
     Mr. Tom Ferraro - Securities and Exchange Commission
     Mr. Kirk L. Somers - Concurrent Computer Corporation
     Ms. Pamela Blackburn - Deloitte & Touche LLP
     Mr. Alan J. Prince - King & Spalding LLP