June 4, 2018

Sally Rau
General Counsel
Cambium Networks Corporation
3800 Golf Road, Suite 360
Rolling Meadows, IL 60008

       Re: Cambium Networks Corporation
           Draft Registration Statement on Form S-1
           Submitted May 8, 2018
           CIK No. 0001738177

Dear Ms. Rau:

       We have reviewed your draft registration statement and have the
following comments. In
some of our comments, we may ask you to provide us with information so we may
understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional

Draft Registration Statement Submitted on May 8, 2018

Prospectus Summary, page 1

1.     Prominently disclose the overview of the restructuring activities
undertaken by Vector
       Capital and affiliates, quantifying the associated charges.
2.     Please include in your Prospectus Summary and in your Business section a
       organization chart that will show the structure of the company after
your recapitalization.
       Include in this chart the voting control that will be held by Vector
Capital and the voting
       control held by public shareholders after the offering and
 Sally Rau
FirstNameNetworks Corporation
Cambium LastNameSally Rau
Comapany NameCambium Networks Corporation
June 4, 2018
June 4, 2018 Page 2
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FirstName LastName
3.       Please balance your disclosure by adding an overview of the risks
related to this offering
         and ownership of your shares by Vector Capital and its affiliates.
Include here any current
         or anticipated waivers of competition and corporate opportunity,
including with which
         individuals and by which agreements or by board action, specified
business opportunities
         or specified classes or categories of business opportunities may be
Risk Factors, page 12

4.       In your disclosure on page 107 you state that you have undesignated
preferred shares and
         that a certain amount of those shares may be issued without
shareholder action. Please
         provide a risk factor discussing these undesignated preferred shares
and the possible
         impact any future issuances may have on common shareholders. Include
this information
         in your Prospectus Summary and in any other location you deem
Our memorandum and articles of association contain anti-takeover provisions
that could have a
material adverse effect..., page 38

5.       Please expand your risk factor here or provide an additional risk
factor to discuss the
         potential impact your staggered board structure may have on
shareholders' ability to exert
         influence on company decisions.
Use of Proceeds, page 45

6.       We note that you intend to dedicate a certain portion of the offering
proceeds to returning
         capital and accumulated yield and to pay management fees to VCH, L.P.
and its affiliates.
         Discuss here, or where you deem appropriate, how you quantified this
amount. Please
         also discuss in your Prospectus Summary and anywhere else you deem
appropriate how
         you considered these payments in your recapitalization plan.
Management's Discussion and Analysis
Overview, page 53

7.       Please enhance the overview of your management's discussion and
analysis to discuss the
         likely impact of known trends, demands, commitments, events or
uncertainties that are
         reasonably likely to have material effects on your financial condition
or results of
         operations. For example, discuss any cost savings initiatives and
other restructuring
         activities undertaken including exiting facilities and reducing your
workforce or relocating
         positions to lower cost geographies that have generated significant
cost savings and
         whether you expect further cost savings to be generated. We also note
that you have
         incurred substantial debt associated with the recapitalization. Please
revise your overview
         to address in more detail how these trends, demands, commitments etc.
are likely to affect
         your financial condition or results of operations. For more
information, refer to the
         Commission Guidance Regarding Management's Discussion and Analysis of
         Condition and Results of Operations (Release Nos. 33-8350, dated
December 29, 2003),
         and Section III of the Interpretive Rule on Management's Discussion
and Analysis
 Sally Rau
FirstNameNetworks Corporation
Cambium LastNameSally Rau
Comapany NameCambium Networks Corporation
June 4, 2018
June 4, 2018 Page 3
Page 3
FirstName LastName
         (Release Nos. 33-6835, 34-26831, dated May 18, 1989).
Results of operations, page 58

8.       We note your disclosure on page 55 regarding share-based compensation
expense. Please
         revise your discussion of the results of operations to clarify which
income statement line
         items are expected to be impacted by the issuance of share-based
compensation in
         connection with this offering. If possible, please also quantify the
expected future impact
         upon each line item. Please refer to Item 303(a)(3)(ii) of Regulation
Regulatory requirements, page 83

9.       Please expand your discussion of regulations to provide more details
about the specific
         laws and regulations that may materially affect your operations.
Executive Compensation, page 91

10.      We note that you have only provided compensation information for the
fiscal year ended
         December 31, 2017. Please provide summary compensation information for
the two most
         recent completed fiscal years. Please refer to Item 402(n) of
Regulation S-K.
Consolidated Financial Statements, page F-1

11.      Please update your financial statements and other financial
information in include the
         interim period ended March 31, 2018. Please refer to Rule 3-12 of
Regulation S-X.
Consolidated Balance Sheets, page F-3

12.      Please present a pro forma balance sheet alongside your most recent
historic balance sheet
         to give effect to the recapitalization and return of capital. The pro
forma balance sheet
         should reflect the return of capital as a distribution accrual, and
not give effect to the
         offering proceeds.
Consolidated Statements of Income, page F-4

13.      Please present on the face of your income statement pro forma per
share data, for the latest
         year and subsequent interim period, to give effect to the
recapitalization and the total
         number of shares whose proceeds would be necessary to pay the return
of capital. We
         refer you to the guidance in SAB Topic 1:B.3.
10. Management incentive compensation, page F-23

14.      Please disclose the types of future triggering events that would cause
you to record
         compensation expense for the MIU and phantom units.
 Sally Rau
Cambium Networks Corporation
June 4, 2018
Page 4
15. Commitments and contingencies, page F-31

15.      We note your disclosures on page 116 regarding registration rights
granted to Vector
         Capital. If material, please disclose any cash penalties associated
with the registration
         rights agreements or penalties resulting from delays in registering
your common stock.
         Please refer to ASC 825-20-50-1.
17. Related party transactions, page F-33

16.      We note Vector Capital Management, LP, provided you with management
oversight and
         services during 2016 and 2017. Please refer to SAB Topic 1:B.1 and
tell us if the historic
         income statements reflect all costs of doing business. With respect to
any expenses
         incurred by your parent on your behalf, please disclose your method of
allocation and
         provide management's assertion that the method used is reasonable.
18. Subsequent events, page F-34

17.      Please disclose the actual date through which subsequent events were
evaluated. Please
         also disclose whether that date represents when the financial
statements were issued or
         available to be issued. Please refer to ASC 855-10-50-1.

18.      We note that you include graphics in your gatefolds to your
registration statement and that
         you include revenue information. Balance out your disclosure by
providing net income
         (loss) information in the locations where you reference revenue and
revenue growth.
19.      Please confirm that the graphics you include in your front and back
gatefolds accurately
         reflect your current product and service capabilities.
20.      We note references to third-party market data throughout the
prospectus. Please provide
         us with copies of any materials that support third-party statements,
clearly cross-
         referencing a statement with the underlying factual support.
        You may contact Lisa Haynes Etheredge, Staff Accountant, at
202-551-3424 or Robert
Littlepage, Accountant Branch Chief, at 202-551-3361 if you have questions
comments on the financial statements and related matters. Please contact
Courtney Lindsay,
Staff Attorney, at 202-551-7237 or Celeste Murphy, Legal Branch Chief, at
202-551-3257 with
any other questions.

FirstName LastNameSally Rau
Comapany NameCambium Networks Corporation
                                                               Division of
Corporation Finance
June 4, 2018 Page 4                                            Office of
FirstName LastName