July 19, 2016
Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Attention: Mr. Carlos Pacho
| Re: | ADTRAN, Inc. |
Form 10-K for Fiscal Year Ended December 31, 2015
Filed February 24, 2016
Form 10-Q for Fiscal Quarter Ended March 31, 2016
Filed May 4, 2016
SEC Comment Letter Dated June 20, 2016
File No. 000-24612
Ladies and Gentlemen:
This correspondence is in response to the letter to ADTRAN, Inc. (the “Company”), dated June 20, 2016 (the “Comment Letter”) from Carlos Pacho, Senior Assistant Chief Accountant, Division of Corporation Finance of the Securities and Exchange Commission.
In connection with the letter from Dentons US LLP, as counsel to the Company, filed on the date hereof in response to the Comment Letter, and as required by the Comment Letter, the Company hereby acknowledges that:
| • | the Company is responsible for the adequacy and accuracy of the disclosure in the filings reviewed by the Staff; |
| • | Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff 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. |
Very truly yours,
/ s / Roger D. Shannon
Roger D. Shannon, Chief Financial Officer
| cc: | Thomas R. Stanton |
Thomas Wardell