[WEIL, GOTSHAL & MANGES LLP LETTERHEAD]

                                 April 21, 2006

VIA EDGAR TRANSMISSION (CORRESP.)

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Mail Stop 3720
Washington, D.C. 20549
Attention: Robert S. Littlepage, Accountant Branch Chief

                           Re:      Comverse Technology, Inc.
                                    Item 4.02 Form 8-K
                                    Filed April 17, 2006
                                    File No. 000-15502

Dear Mr. Littlepage:

Reference is made to the comments of the Staff of the Securities and Exchange
Commission (the "Commission" or the "Staff") with respect to the above
referenced Current Report on Form 8-K ("Form 8-K") of Comverse Technology, Inc.
(the "Company") in the letter dated April 18, 2006 (the "Comment Letter").

On behalf of the Company, we are writing to respond to the comments raised in
the Staff's Comment Letter. The numbered paragraphs below correspond to the
numbers set forth in the Comment Letter. The text of the Staff's comments is
copied below in bold for your reference.

1    TELL US WHEN YOU ANTICIPATE COMPLETION OF THE SPECIAL COMMITTEE'S REVIEW
     AND THE FILING OF YOUR RESTATEMENTS.

          As disclosed in the Form 8-K, the Special Committee has not yet
          completed its work or reached final conclusions and is continuing its
          review. The Special Committee has not indicated to the Company when it
          anticipates completing its review. The results of such review are
          likely to affect the nature and extent of any restatements and the
          amount of time and effort required by the Company to prepare any
          necessary restatements and for the Company's independent registered
          accounting firm to complete its review of such restatements. The
          completion time of the Special Committee review, the extent of its
          findings and the procedures that will be required by the Company's
          independent registered accounting firm in connection with its review
          of any restatements are beyond the Company's control. Accordingly, the
          Company is unable at this time to provide the Staff with an estimate
          of the time by which the Company will be able to file any
          restatements.


2    WHEN YOU AMEND YOUR PERIODIC REPORTS TO FILE YOUR RESTATED FINANCIAL
     STATEMENTS, DESCRIBE THE EFFECT OF THE RESTATEMENT ON THE OFFICERS'
     CONCLUSIONS REGARDING THE EFFECTIVENESS OF THE COMPANY'S DISCLOSURE
     CONTROLS AND PROCEDURES. SEE ITEM 307 OF REGULATION S-K. IF THE OFFICERS
     CONCLUDE THAT THE DISCLOSURE CONTROLS AND PROCEDURES WERE EFFECTIVE,
     DESPITE THE RESTATEMENT, DESCRIBE THE BASIS FOR THE OFFICERS' CONCLUSIONS.

          The Company will comply with the Staff's comment when is amends its
          periodic reports to file its restated financial statements.

     The Company's acknowledgment of the matters specified in the Comment Letter
is attached to this letter as Exhibit A.

     If you or any other member of the Staff has any further questions or
comments concerning the foregoing responses, please contact the undersigned at
(212) 310-8220.



                                                 Sincerely,

                                                 /s/ DAVID E. ZELTNER
                                                 David E. Zeltner, Esq.


cc:      Paul L. Robinson, Esq.
         General Counsel and V.P. - Legal
         Comverse Technology, Inc.


                                                                       EXHIBIT A

                        [COMVERSE TECHNOLOGY, INC. LETTERHEAD]

                                                                  April 21, 2006

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Mail Stop 3720
Washington, D.C. 20549
Attention: Robert S. Littlepage, Accountant Branch Chief

                           Re:      Comverse Technology, Inc.
                                    Item 4.02 Form 8-K
                                    Filed April 17, 2006
                                    File No. 000-15502

Dear Mr. Littlepage:

     Reference is made to the comments of the Staff of the Securities and
Exchange Commission (the "Commission" or the "Staff") with respect to the above
referenced Current Report on Form 8-K of Comverse Technology, Inc. (the
"Company") in the letter dated April 18, 2006 (the "Comment Letter").

     As requested in the Comment Letter, the Company hereby acknowledges that:

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

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

          o    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.


                                    COMVERSE TECHNOLOGY, INC.

                                    By:    /s/ Paul L. Robinson
                                           -------------------------------------
                                    Name:  Paul L. Robinson
                                    Title: General Counsel and V.P.-Legal