RONSON                                                         EXECUTIVE OFFICES
CORPORATION

RONSON RD                                                TELEPHONE: 732-636-2430
P.O. BOX 3000 WOODBRIDGE, NEW JERSEY 07095


                                                                October 13, 2009
Mr. Rufus Decker
Accounting Branch Chief
Division of Corporation Finance
Mail Stop 4631
U.S. Securities and Exchange Commission
Washington, DC 20549-4631

      RE:   Form 10-K for the fiscal year ended December 31, 2008
            Forms 10-Q for the periods ended March 31, 2009 and June 30, 2009
            File No. 1-1031

Dear Mr. Decker:

On  behalf of  Ronson  Corporation  (the  "Company"),  set  forth  below are our
responses to the additional  comments  raised in your letter dated September 30,
2009 (the  "Comment  Letter")  regarding  our Annual Report on Form 10-K for the
fiscal year ended  December  31, 2008 (the "Annual  Report")  and our  Quarterly
Reports on Form 10-Q for the periods ended March 31, 2009 and June 30, 2009 (the
"Quarterly  Reports").  The  responses  below are in the same order in which the
Comment  Letter  was  written  with  each  response  immediately  following  the
corresponding comment each of which is re-typed below.

Also, in connection with this response, we acknowledge the following:

      o     the Company is  responsible  for the  adequacy  and  accuracy of the
            disclosure in these filings;

      o     staff  comments  or  changes  to  disclosure  in  response  to staff
            comments do not foreclose the Commission from taking any action with
            respect to the filings; and

      o     the  Company  may not  assert  staff  comments  as a defense  in any
            proceedings  initiated  by the  Commission  or any person  under the
            federal securities laws of the United States.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2008
- ----------------------------------------------

General
- -------

      1.  Where  a  comment  below  requests  additional  disclosures  or  other
revisions  to be made,  please show us in your  supplemental  response  what the
revisions  will  look  like.  With the  exception  of the  comments  below  that
specifically  request an amendment,  all other revisions may be included in your
future filings.

We note the  staff's  comment and have  responded  accordingly  to the  comments
below.

Item 15 - Exhibits and Financial Statement Schedules, page 42
- -------------------------------------------------------------

Note 4 - Long-term debt, page 62
- --------------------------------

      2. We have reviewed  your response to prior comment 5. You have  responded
that you will reclassify your loan balances as short-term in future filings.  As
previously requested,  please tell us how you applied the guidance in EITF 86-30
in  determining  that a portion of your loan balances  should  appropriately  be
classified as long-term.  Please separately address the  appropriateness of your
long-term classification pursuant to EITF 86-30 as of December 31, 2008 and each
subsequent interim balance sheet date.


Mr. Rufus Decker                                                October 13, 2009
Page 2 of 2

The loan agreement with our primary lender, under Section 6.2(e),  provides that
"for  the  fiscal   year  ending   December   31,  2009  and  each  fiscal  year
thereafter...Lender shall consult with ...[the Company] and thereafter reset the
.... Financial Covenants in its reasonable  discretion." As previously indicated,
the Company's primary lender has not taken action to exercise its remedies under
our loan arrangements which we viewed as tantamount to a waiver of compliance on
December 31, 2008 and, in the context of EITF 86-30 and our loan  agreement,  an
implicit  on-going  modification of our compliance  requirements so as to render
the  covenants   reasonable  in  our   circumstances.   In  view  of  subsequent
developments  and our  on-going  communication  with the primary  lender and our
reexamination  of the  guidance  under EITF  86-30,  we  believe  that our prior
interpretation does not apply and, as previously indicated, in future filings we
will classify the Company's loan balances as short-term.

Exhibit 31 -- Certifications
- ----------------------------

      3. We have  reviewed  your  response to prior comment 6. Please amend your
December  31,  2008 Form 10-K,  as well as your March 31, 2009 and June 30, 2009
Forms 10-Q, to provide the  certifications of Section 302 of the  Sarbanes-Oxley
Act of 2002 that conform to the language in Item  601(B)(31) of Regulation  S-K.
Specifically, please:

      o     include in your  certifications  in the  December 31, 2008 Form 10-K
            and the March 31, 2009 and June 30, 2009 Forms 10-Q the phrase, "and
            internal  control over  financial  reporting (as defined in Exchange
            Act  Rules  13a-15(f)  and  15d-15(f))"  in  the   introduction  for
            paragraph 4;

      o     include in your  certifications  in the  December 31, 2008 Form 10-K
            and the June 30, 2009 Form 10-Q  paragraph 4(b) regarding the design
            of your internal control over financial reporting; and

      If there are no restatements  made to the financial  statements,  the Form
10-K/A  and  subsequent   Forms  10-Q/A  can  solely  include  the  cover  page,
explanatory note, signature page, and Items 1, 2, 4 and 5 of the certifications.
Please ensure that the revised certifications refer to the Form 10-K/A and Forms
10-Q/A and are  currently  dated.  Refer to Section  246.13 of the  Division  of
Corporation   Finance  -  Compliance  and  Disclosure   Interpretations  of  the
Regulation S-K, which can be found at
http://www.sec.gov/divisions/corpfin/guidance/regs-kinterp.htm.
- ---------------------------------------------------------------

We  will  amend  our  Annual  Report  and  Quarterly   Reports  to  provide  the
certifications of Section 302 of the  Sarbanes-Oxley Act of 2002 that conform to
the language contained in Item 601(B)(31) of Regulation S-K and as requested.


                                     * * * *


In the event that you have any  questions  regarding  our  responses  or require
additional information, please contact me at (732) 438-0320.

                                                 Very truly yours,

                                                 /s/ Daryl Holcomb

                                                 Daryl Holcomb
                                                 Chief Financial Officer



cc:   Jeffrey Gordon, Staff Accountant