RONSON                                                         EXECUTIVE OFFICES
CORPORATION

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




VIA EDGAR TRANSMISSION                                         December 22, 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/A for the fiscal year ended December 31, 2008
            Forms 10-Q/A 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  December 2,
2009 (the "Comment  Letter")  regarding our amended Annual Report on Form 10-K/A
for the fiscal  year ended  December  31,  2008 (the  "Annual  Report")  and our
amended  Quarterly  Reports on Form 10-Q/A 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/A  FOR THE YEAR  ENDED  DECEMBER  31,  2008 AND FORMS  10-Q/A FOR THE
- --------------------------------------------------------------------------------
PERIODS ENDED MARCH 31, 2009 AND JUNE 30, 2009
- ----------------------------------------------

Item 9A(T) - Controls and Procedures, page 14
- ---------------------------------------------

1. We previously  requested  that you consider the impact that your  restatement
had on your original  conclusions  regarding the  effectiveness of your internal
controls over  financial  reporting as of December 31, 2008 and your  disclosure
controls and  procedures  as of December  31, 2008,  March 31, 2009 and June 30,
2009. We note from your  disclosure  that your  management  has  concluded  that
despite the  restatements  your internal  control over  financial  reporting was
effective as of December 31, 2008 and your  disclosure  controls and  procedures



Mr. Rufus Decker                                               December 22, 2009
Page 2 of 2

were  effective as of December 31,  2008,  March 31, 2009 and June 30, 2009.  As
defined in Rule 13a-15(e), disclosure controls and procedures are those designed
to ensure that  information  required to be disclosed  is  recorded,  processed,
summarized and recorded within specified time periods and are designed to ensure
that information that is required to be disclosed by you in the reports that you
file or submit under the Exchange Act is accumulated  and  communicated  to your
management.  EITF 86-30 requires the debt that is the subject of the restatement
be classified as current and you  classified it as  non-current in your original
Form 10-K for the year ended  December  31, 2008 and interim  Forms 10-Q for the
periods  ended  March 31,  2009 and June 30,  2009.  In  addition,  the  amounts
restated  resulted in a material change in your current  liabilities and working
capital  (deficit).  Thus, we do not understand  how you determined  information
required to be  disclosed  in the  original  filings was in fact  disclosed.  In
addition,  please  explain to us why this  correction  of an error  would not be
considered  a  material   weakness  in  your  internal  control  over  financial
reporting. As such, it is still not clear how you arrived at the conclusion that
your  disclosure  controls and  procedures  and internal  control over financial
reporting  are   effective.   Please  revise  your   disclosure   regarding  the
effectiveness  of your disclosure  controls and procedures and internal  control
over financial  reporting in your Forms 10-K/A and 10-Q/A to provide an enhanced
discussion  of the factors you  considered  and highlight any other factors that
support your conclusion.  If upon further reflection you determine your internal
control over financial reporting as of December 31, 2008 and disclosure controls
and  procedures  as of December 31, 2008,  March 31, 2009 and June 30, 2009 were
not effective, please revise your disclosures accordingly.

As indicated  in our prior  responses  to the Staff's  comments  relating to the
application of the guidance  contained in EITF 86-30, we indicated the basis for
our position and our  interpretation  and  application  of that  guidance to our
circumstances.   We  did  not  believe  that  a   reasonable,   though   flawed,
interpretation of the guidance resulted in a material weakness.  Further,  as we
believed  the   interpretation   and  application  of  available   guidance  was
reasonable,  we did not  conclude  that  there was a failure  in the  disclosure
controls that the Company has in place.  Upon further  reflection,  as the Staff
has  suggested,  we have  determined  that our internal  control over  financial
reporting was not effective as of December 31, 2008 and our disclosure  controls
and  procedures  as of  December  31,  2008,  March 31,  2009 and June 30,  2009
similarly were not effective.  We have revised our  disclosures in amendments to
each of the  applicable  reports  which are being filed  concurrently  with this
response.

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

2.  Please  amend your  December  31, 2008 Form 10-K/A as well as your March 31,
2009 and June 30, 2009 Forms 10-Q/A 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. The  certifications  included in your December 31,
2008 Form 10-K/A omit the language required by paragraph 2. Instead you included
the  language  required  by  paragraph  3  within  paragraph  2.  Further,   the
certifications  included in your March 31,  2009 and June 30, 2009 Forms  10-Q/A
omit the  language  required  by  paragraph  3.  Since  you  restated  financial
statements  in your December 31, 2008 Form 10-K/A as well as your March 31, 2009
and June 30, 2009 Forms 10-Q/A,  you must provide complete  certifications  that
conform to the language in Item  601(B)(31) of Regulation  S-K. Please note that
when you amend your Form 10-K/A to provide the revised 302  certifications,  the
certifications  should refer to your amended  filings in the first paragraph and
be currently dated.

We have revised our certifications in each of the Form 10-K/A for the year ended
December 31, 2008 and the Forms 10-Q/A for the quarters ended March 31, 2009 and
June 30, 2009 which are being filed concurrently with this response.

                                     * * * *

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