UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

BRICKMAN INVESTMENTS INC., on

behalf of itself and all others similarly situate,

Plaintiff,

v.

ALLOT COMMUNICATIONS LTD.,

YIGAL JACOBY, RAMI HADAR and ADI

SAPIR,

Defendants.

No. 1:07-cv-03455-RJH

[PROPOSED] ORDER GRANTING

MOTION OF DIKLA MONDIAL MUTUAL

FUND FOR CONSOLIDATION OF

RELATED ACTIONS, APPOINTMENT AS

LEAD PLAINTIFF AND APPROVAL OF

LEAD PLAINTIFF’S SELECTION OF COLEAD COUNSEL

GERALD BILGER, individually and on

behalf of all others similarly situated,

Plaintiff,

v.

ALLOT COMMUNICATIONS LTD.,

YIGAL JACOBY, RAMI HADAR and ADI

SAPIR,

Defendants.

No. 1:07-cv-03815-RJH

ELIYAHU MOKHTAR, individually and on

behalf of all others similarly situated,

Plaintiff,

v.

ALLOT COMMUNICATIONS LTD.,

YIGAL JACOBY, RAMI HADAR and ADI

SAPIR,

Defendants.

No. 1:07-cv-05456-RJH

[Captions Continue on Following Page]

Case 1:07-cv-03455-RJH Document 8-2 Filed 07/02/2007 Page 1 of 5
- 1 -

SHANNON VINSON, individually and on

behalf of all others similarly situated,

Plaintiff,

v.

ALLOT COMMUNICATIONS LTD.,

YIGAL JACOBY, RAMI HADAR and ADI

SAPIR,

Defendants.

No. 1:07-cv-05457-RJH

[PROPOSED] ORDER

Having considered the motion of Dikla Mondial Mutual Fund for consolidation of related

actions, for appointment as Lead Plaintiff and for approval of Lead Plaintiff=s selection of CoLead Counsel, the memorandum of law in support thereof, the declaration of Dale MacDiarmid

in support of that motion and good cause appearing therefor,

IT IS HEREBY ORDERED:

1) The Motion is granted.

2) This Order (the “Order”) shall apply to the above-captioned actions (the “Action”)

and to each case that relates to the same subject matter that is subsequently filed in this Court or

is transferred to this Court and consolidated with the Action (collectively, the “Consolidated

Action”).

3) An original of this Order shall be filed by the Clerk in the Master File.

4) The Clerk shall mail a copy of this Order to counsel of record in the Consolidated

Action.

5) Every pleading in the Consolidated Action shall have the following caption:

IN RE ALLOT COMMUNICATIONS LTD.

SECURITIES LITIGATION

No. 1:07-cv-03455-RJH

Case 1:07-cv-03455-RJH Document 8-2 Filed 07/02/2007 Page 2 of 5
- 2 -

6) Each new case that arises out of the subject matter of the Consolidated Action

which is filed in this Court or transferred to this Court, shall be consolidated with the

Consolidated Action and this Order shall apply thereto, unless a party objects to consolidation, as

provided for herein, or any provision of this Order, within ten (10) days after the date upon which

a copy of this Order is served on counsel for such party, by filing an application for relief and this

Court deems it appropriate to grant such application. Nothing in the foregoing shall be construed

as a waiver of Defendants’ right to object to consolidation of any subsequently filed or

transferred related action.

7) The Court requests the assistance of counsel in calling attention to the Clerk of

this Court the filing or transfer of any case that might properly be consolidated as part of the

Consolidated Action.

8) When a case that arises out of the same subject matter as the Consolidated Action

is hereinafter filed in this Court or transferred from another Court, the Clerk of this Court shall:

a) file a copy of this Order in the separate file for such action;

b) mail a copy of this Order to the attorneys for the plaintiff(s) in the newly

filed or transferred case and to any new defendant(s) in the newly filed case; and

c) make the appropriate entry in the Master Docket for the Consolidated

Action.

9) Movant Dikla Mondial Mutual Fund is appointed to serve as Lead Plaintiff in the

above-captioned Consolidated Action, pursuant to 15 U.S.C. §77z-1(a)(3)(B).

10) The law firms Glancy Binkow & Goldberg LLP and The Law Office of Jacob

Sabo are hereby approved as Co-Lead Counsel for the Class. Lead Counsel shall provide general

supervision of the activities of plaintiff=s counsel and shall have the following responsibilities

and duties to perform or delegate as appropriate:

a) to brief and argue motions;

b) to initiate and conduct discovery, including, without limitation,

coordination of discovery with defendants’ counsel, preparation of written interrogatories,

requests for admission and requests for production of documents;

Case 1:07-cv-03455-RJH Document 8-2 Filed 07/02/2007 Page 3 of 5
- 3 -

c) to direct and coordinate the examination of witnesses in depositions;

d) to act as spokesperson at pretrial conferences;

e) to call and chair meetings of plaintiff’s counsel as appropriate or necessary

from time to time;

f) to initiate and conduct any settlement negotiations with counsel for

defendants;

g) to provide general coordination of the activities of plaintiff’s counsel and

to delegate work responsibilities to selected counsel as may be required in such a manner as to

lead to the orderly and efficient prosecution of this litigation and to avoid duplication or

unproductive effort;

h) to consult and employ experts;

i) to receive and review periodic time reports of all attorneys on behalf of

plaintiffs, to determine if the time is being spent appropriately and for the benefit of plaintiffs

and to determine and distribute plaintiffs’ attorneys’ fees; and

j) to perform such other duties as may be expressly authorized by further

order of this Court.

i) The law firm of Murray, Frank & Sailer LLP is hereby approved as

Liaison Counsel for the Class.

Dated: ________________, 2007

____________________________________

U.S.D.J.

Case 1:07-cv-03455-RJH Document 8-2 Filed 07/02/2007 Page 4 of 5
- 4 -

Submitted by:

Brian P. Murray

MURRAY, FRANK & SAILER LLP

275 Madison Avenue, Suite 801

New York, New York 10016

Telephone: (212) 682-1818

Facsimile: (212) 682-1892

Proposed Liaison Counsel

GLANCY BINKOW & GOLDBERG LLP

Lionel Z. Glancy

Michael Goldberg

1801 Avenue of the Stars, Suite 311

Los Angeles, CA 90067

Telephone: (310) 201-9150

Facsimile: (310) 201-9160

THE LAW OFFICE OF JACOB SABO

Jacob Sabo

The Tower No.3 Daniel Frisch St. 15th Floor

Tel Aviv, Israel 64731

Telephone: 011 972 3 607 88 88

Facsimile: 011 972 3 607 88 89

Attorneys for Movant and

Proposed Co-Lead Counsel

Case 1:07-cv-03455-RJH Document 8-2 Filed 07/02/2007 Page 5 of 5