6500 Chase Oaks Boulevard, Suite 100

Plano, Texas 75023


September 21, 2022




United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549


  Re: Ribbon Communications Inc.
    Registration Statement on Form S-3
    Filed September 14, 2022
    File No. 333-267415


Ladies and Gentlemen:


On behalf of Ribbon Communications Inc. (the “Company”), the undersigned hereby requests, pursuant to Rule 461 under the Securities Act of 1933, as amended, that the effective time of the Registration Statement on Form S-3 of the Company be accelerated to 5:00 p.m., Eastern Time, on September 23, 2022, or as soon as practicable thereafter. The Company respectfully requests that you notify Patrick Macken by a telephone call to (978) 614-8170 of such effectiveness.


Please contact Betty Linkenauger Segaar of Troutman Pepper Hamilton Sanders LLP at (804) 697-2328 if you have any questions concerning this matter. Thank you for your continued attention to this matter.


  Very truly yours,
  By: /s/ Patrick Macken
  Name: Patrick Macken
  Title: Executive Vice President, Chief Legal Officer and Corporate Secretary


cc: David W. Ghegan, Esq., Troutman Pepper Hamilton Sanders LLP
  Betty Linkenauger Segaar, Esq., Troutman Pepper Hamilton Sanders LLP