United States securities and exchange commission logo

                             November 30, 2021

       Bruce McClelland
       President and Chief Executive Officer
       Ribbon Communications Inc.
       6500 Chase Oaks Boulevard
       Suite 100
       Plano, Texas 75023

                                                        Re: Ribbon
Communications Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed February 26,
                                                            File No. 001-38267

       Dear Mr. McClelland:

              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 Fiscal Year Ended December 31, 2020

       Consolidated Statements of Operations, page 62

   1.                                                   We note that you offer
Software-as-a-Service (   SaaS   ) subscriptions. Please tell us the
                                                        amount of revenue
recognized from SaaS subscriptions for the periods presented and in
                                                        which line item they
are reflected in your Statements of Operations. Refer to Rule 5-03(b)
                                                        of Regulation S-X.
   2.                                                   We note that cost of
revenue excludes the amortization of acquired intangibles and that
                                                        you present gross
profit which excludes these expenses. Please tell us how your
                                                        presentation complies
with SAB Topic 11.B. In this regard, if you do not allocate this
                                                        amortization to cost of
revenue, you should remove the gross profit subtotal from your
                                                        statements of
operations and re-label the cost of revenue line item to indicate that it
                                                        excludes amortization.
 Bruce McClelland
FirstName LastNameBruce   McClelland
Ribbon Communications  Inc.
Comapany 30,
November  NameRibbon
              2021     Communications Inc.
Page 2    30, 2021 Page 2
FirstName LastName
Note 18. Operating Segment Information, page 100

3.       We note that you present segment adjusted gross profit and segment
adjusted EBITDA as
         segment measures of profit or loss used to assess segment performance.
If the CODM
         uses more than one measure of a segment's profit or loss, the reported
(single) measure
         shall be the one that management believes is determined in accordance
with the
         measurement principles most consistent with those used in measuring
the corresponding
         amount in your consolidated financial statements. Refer to ASC
280-10-50-22 and -28.
         Please tell us your consideration of disclosing only one measure of
segment profit or loss.
       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 Megan Akst, Senior Staff Accountant at 202-551-3407 or
Dietz, Senior Staff Accountant at 202-551-3408 with any questions.


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