February 26, 2025

Michael Bondi
Chief Financial Officer
Comtech Telecommunications Corp.
305 N 54th Street
Chandler, AZ 85226

       Re: Comtech Telecommunications Corp.
           Form 10-K for the Fiscal Year Ended July 31, 2024
           Form 10-Q for the Fiscal Quarter Ended October 31, 2024
           File No. 000-07928
Dear Michael Bondi:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended July 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies
Revenue Recognition, page 60

1.     We note from disclosures elsewhere in your filing that for certain
contracts you
       recognize revenue over time under the cost-to-cost method which requires
subjective
       judgment and estimation to determine total costs expected to be incurred
at contract
       completion. You indicate such estimates for significant contracts are
reviewed and
       reassessed at least quarterly and any changes in estimates may impact
current period
       earnings through a cumulative adjustment. You also indicate provisions
for estimated
       losses on uncompleted contracts are made in the period such losses are
determined,
       and on page 67 you indicate that higher expected costs at completion
contributed to
       the decline in gross profit margin in fiscal 2024 for your Satellite and
Space
       Communications segment. Please address the following items.
           Tell us whether you have recognized material favorable or
unfavorable changes in
 February 26, 2025
Page 2

           estimates with respect to these contracts and provide us the gross
amounts of
           favorable and unfavorable changes recognized during each period
presented as
           part of your response.
             Tell us the amount of contract losses recognized during each
period presented and
           the status of material loss contracts.
             Revise your disclosures in future filings to quantify and discuss
the gross impacts
           of changes in contract estimates, including contract losses, during
each period
           presented pursuant to Item 303(b)(3) of Regulation S-K.
Financial Statements for the Fiscal Year Ended July 31, 2024
Note 12. Segment Information, page F-40

2.     You appear to identify Adjusted EBITDA as your segmental measure of
profit or loss.
       In addition to providing this segment measure of profitability for each
of your
       reportable segments in accordance with ASC 280-10-50-22, you present an
Adjusted
       EBITDA amount for each of your "Unallocated" column and "Total" column.
Please
       note that ASC 280 requires disclosure of the profitability measure for
each segment
       only, and disclosure of a consolidated Adjusted EBITDA amount is
therefore
       considered a Non-GAAP financial measure and as such should not be
disclosed in the
       notes to the financial statements under the guidance in Item
10(e)(1)(ii)(C) of
       Regulation S-K. Please revise future filings to remove the unallocated
and
       consolidated Adjusted EBITDA amounts.
Form 10-Q for the Fiscal Quarter Ended October 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 42

3.     We note from the reconciliation of your non-GAAP measures beginning on
page 55
       that each of your non-GAAP measures includes an adjustment for an item
titled
       "restructuring costs." It appears from your disclosures that your fiscal
2025
       restructuring costs include a non-cash inventory write-down of $11.4
million related
       to certain products that were either discontinued or are being
de-emphasized going
       forward as a result of review of your product portfolio. Please explain
to us why you
       believe that this inventory write-down adjustment does not represent
costs that are
       normal operating costs of the business, or alternatively please revise
future filings to
       remove inventory write-down adjustments from your non-GAAP measures. See
       guidance in Question 100.01 of the SEC Staff   s Compliance & Disclosure
       Interpretations on Non-GAAP Financial Measures. Your disclosures in your
earnings
       release furnished on Form 8-K should be similarly revised.
 February 26, 2025
Page 3

        In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

       Please contact Jennifer Thompson at 202-551-3737 or Hugh West at
202-551-3872
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing