0001213900-21-007958.txt : 20210311 0001213900-21-007958.hdr.sgml : 20210311 20210210101234 ACCESSION NUMBER: 0001213900-21-007958 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20210210 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ComSovereign Holding Corp. CENTRAL INDEX KEY: 0001178727 STANDARD INDUSTRIAL CLASSIFICATION: COMMUNICATIONS EQUIPMENT, NEC [3669] IRS NUMBER: 465538504 STATE OF INCORPORATION: NV FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 5000 QUORUM DRIVE, SUITE 400 CITY: DALLAS STATE: TX ZIP: 75254 BUSINESS PHONE: 904-834-4400 MAIL ADDRESS: STREET 1: 5000 QUORUM DRIVE, SUITE 400 CITY: DALLAS STATE: TX ZIP: 75254 FORMER COMPANY: FORMER CONFORMED NAME: ComSovereign Holding Corp DATE OF NAME CHANGE: 20191210 FORMER COMPANY: FORMER CONFORMED NAME: DRONE AVIATION HOLDING CORP. DATE OF NAME CHANGE: 20140508 FORMER COMPANY: FORMER CONFORMED NAME: MACROSOLVE INC DATE OF NAME CHANGE: 20020725 CORRESP 1 filename1.htm

ComSovereign Holding Corp.

5000 Quorum Drive, STE 400

Dallas, TX 75254

February 10, 2021

VIA EDGAR

Mr. Tom Jones

Securities and Exchange Commission

Division of Corporate Finance

Office of Manufacturing

100 F Street, N.E.

Washington, D.C. 20549

Re:

ComSovereign Holding Corp.

Registration Statement on Form S-1

File No. 333-252780

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, ComSovereign Holdings Inc. (the “Company”) hereby requests that the above-captioned registration statement (the “Registration Statement”) be declared effective at 4:00 p.m., Eastern Time, on Wednesday, February 10, 2021, or as soon thereafter as may be practicable.

We acknowledge that a declaration by the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, that the Registration Statement is effective does not foreclose the Commission from taking any action with respect to the Registration Statement. We further acknowledge that such a declaration of effectiveness does not relieve the Company from our full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement. We understand that we may not assert staff comments to the Registr

ation Statement or the declaration of effectiveness by the Commission as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you have any questions, please do not hesitate to contact Eric M. Hellige at Pryor Cashman LLP, outside counsel to the Company, at ehellige@pryorcashman.com (telephone 212-326-0846).

	Very truly yours,

	/s/Daniel L. Hodges
	Daniel L. Hodges
	Chief Executive Officer

cc:

Eric M. Hellige, Esq.