RONSON                                                         EXECUTIVE OFFICES
CORPORATION

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


                                                             November 2, 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  October 14,
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
- ----------------------------------------------

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

Note 4 - Long Debt, page 62
- ---------------------------

      1. We have  reviewed  your  response  to prior  comment  2. Your  response
indicates that your primary lender has not taken action to exercise its remedies
under  your loan  arrangements,  which you viewed as  tantamount  to a waiver of
compliance on December 31, 2008 and an implicit  on-going  modification  of your
compliance  requirements  so as to  render  the  covenants  reasonable  in  your
circumstances.   EITF  86-30  states  that  the  borrower  should  classify  the
obligation  as  noncurrent  unless (a) a covenant  violation has occurred at the
balance sheet date or would have occurred absent a loan  modification and (b) it
is  probable  that  the  borrower  will  not be  able  to cure  the  default  at
measurement  dates  that are  within the next  twelve  months.  We note that you
subsequently  entered into a forbearance  agreement  with your primary lender on
March 30, 2009. As such, it is not clear how you concluded on December 31, 2008





                                                             November 2, 2009

Mr. Rufus Decker
Page 2 of 2

that it was probable  that you would be able to cure the default at  measurement
dates within the  subsequent  twelve  months.  As previously  requested,  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.

We note the  Staff's  comment  and advise  the Staff  that we  believe  that our
analysis of the Company's  circumstances  was consistent  with a reading of EITF
86-30 at each of the dates referenced.

First,  at December  31,  2008,  while we were not in  compliance  with our loan
requirements  under  our  loan  arrangements  with  our  primary  lender,  as we
previously  indicated, our primary lender had  not  taken any action to exercise
its remedies  under our loan  arrangements  which we viewed as  tantamount  to a
waiver of compliance on such date and an implicit  modification of the financial
covenants contained in such loan arrangements.

Second,  while it was  probable at such date that we would not have been able to
cure the default at the measurement  dates within the next twelve months had the
financial  covenants  applicable  to December 31, 2008  continued to apply,  the
specific  circumstances of our loan agreement  support periodic changes in these
covenants. Section 6.2(e) of our loan agreement provides that the primary lender
shall "reset the foregoing Financial Covenants in its reasonable discretion" and
we viewed our lender's  failure to reset our financial  covenants as an implicit
on-going  modification  of  our  compliance  requirements  so as to  render  the
covenants reasonable in our circumstances.  This modification we believe applied
at both  the  end of the  first  quarter  and  the  end of the  second  quarter,
notwithstanding the forbearance  agreement (since the forbearance  agreement did
not formally reset the financial covenants).  We believe this allowed us to view
our analysis of our circumstances as consistent with EITF 86-30.

As previously  indicated,  in view of subsequent  developments  and our on-going
communication  with our primary  lender and our  reexamination  of the  guidance
under EITF 86-30,  we believe that our prior  interpretation  does not now apply
and, as previously  indicated,  in future filings we will classify the Company's
loan balances as short-term.

                                     * * * *


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