0001104659-21-035651.txt : 20210412 0001104659-21-035651.hdr.sgml : 20210412 20210312170146 ACCESSION NUMBER: 0001104659-21-035651 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20210312 FILER: COMPANY DATA: COMPANY CONFORMED NAME: COMTECH TELECOMMUNICATIONS CORP /DE/ CENTRAL INDEX KEY: 0000023197 STANDARD INDUSTRIAL CLASSIFICATION: RADIO & TV BROADCASTING & COMMUNICATIONS EQUIPMENT [3663] IRS NUMBER: 112139466 STATE OF INCORPORATION: DE FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 68 SOUTH SERVICE ROAD STREET 2: SUITE 230 CITY: MELVILLE STATE: NY ZIP: 11747 BUSINESS PHONE: 6319627000 MAIL ADDRESS: STREET 1: 68 SOUTH SERVICE ROAD STREET 2: SUITE 230 CITY: MELVILLE STATE: NY ZIP: 11747 FORMER COMPANY: FORMER CONFORMED NAME: COMTECH INC DATE OF NAME CHANGE: 19870503 FORMER COMPANY: FORMER CONFORMED NAME: COMTECH TELECOMMUNICATIONS CORP DATE OF NAME CHANGE: 19831215 FORMER COMPANY: FORMER CONFORMED NAME: COMTECH LABORATORIES INC DATE OF NAME CHANGE: 19780425 CORRESP 1 filename1.htm

VIA EDGAR

March 12, 2021

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Beverly Singleton

Re:

Comtech Telecommunications Corp./DE

Registration Statement on Form S-3/A

Initially filed March 3, 2021

File No. 333-253827

Comtech Telecommunications Corp. (the “Registrant”) hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) take appropriate action to cause the above-referenced Registration Statement on Form S-3 to become effective at 4:00 p.m. Eastern Time on Monday, March 15, 2021, or as soon thereafter as is practicable. The Registrant also hereby requests a copy of the written order verifying the effective date.

In connection with the foregoing request, the Registrant hereby acknowledges that:

should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

the Registrant may not assert Staff comments and the declaration of effectiveness 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,

COMTECH TELECOMMUNICATIONS CORP.

By:

/s/ Michael A. Bondi

Name: Michael A. Bondi
Title: Chief Financial Officer

Cc:

Fred Kornberg, Comtech Telecommunications Corp.
Michael D. Porcelain, Comtech Telecommunications Corp.
Robert A. Cantone, Proskauer Rose LLP
Daniel L. Forman, Proskauer Rose LLP