Correspondence 0001193125-23-167399 from ASTRONICS CORP (ATRO, ATROB) (CIK 0000008063) (ATRO)
ASTRONICS CORP (ATRO, ATROB) (CIK 0000008063)
Date: June 15, 2023 · CIK: 0000008063 · Accession: 0001193125-23-167399
AI Filing Summary & Sentiment
File numbers found in text: 333-272423
Letter
ASTRONICS CORPORATION
130 COMMERCE WAY
EAST AURORA, NEW YORK 14052
June 15, 2023
VIA EDGAR TRANSMISSION
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Erin Donahue
Re:
Astronics Corporation (Registrant)
Astronics Advanced Electronic Systems Corp. (Additional Registrant)
Astronics Test Systems Inc. (Additional Registrant)
Astronics AeroSat Corporation (Additional Registrant)
Astronics Connectivity Systems & Certification Corp. (Additional Registrant)
Luminescent Systems, Inc. (Additional Registrant)
Freedom Communication Technologies Inc. (Additional Registrant)
PECO, Inc. (Additional Registrant)
Diagnosys Holdings Inc. (Additional Registrant)
Astronics Custom Control Concepts Inc. (Additional Registrant)
Astronics DME LLC (Additional Registrant)
Diagnosys Inc. (Additional Registrant)
Astronics Air LLC (Additional Registrant)
Astronics Air II LLC (Additional Registrant)
Registration Statement on Form S-3 (File No. 333-272423)
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-3 (File No. 333-272423) (the “Registration Statement”) of Astronics Corporation, a New York corporation, Astronics Advanced Electronic Systems Corp., a Washington corporation, Astronics Test Systems Inc., a Delaware corporation, Astronics AeroSat Corporation, a New Hampshire corporation, Astronics Connectivity Systems & Certification Corp., an Illinois corporation, Luminescent Systems, Inc., a New York corporation, Freedom Communication Technologies Inc., a Delaware corporation, PECO, Inc., an Oregon corporation, Diagnosys Holdings Inc., a Delaware corporation, Astronics Custom Control Concepts Inc., a Washington corporation, Astronics DME LLC, a Florida limited liability company, Diagnosys Inc., a Delaware corporation, Astronics Air LLC, a New York limited liability company and Astronics Air II LLC, a New Hampshire limited liability company. We respectfully request that the Registration Statement become effective as of 4:30 p.m., Eastern Time, on June 20, 2023, or as soon thereafter as is practicable. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Hodgson Russ LLP, by calling Craig M. Fischer at (716) 848-1266.
If you have any questions regarding the foregoing, please do not hesitate to contact Craig M. Fischer of Hodgson Russ LLP at (716) 848-1266. Thank you in advance for your consideration.
Very truly yours,
ASTRONICS CORPORATION
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CORRESP 1 filename1.htm CORRESP ASTRONICS CORPORATION 130 COMMERCE WAY EAST AURORA, NEW YORK 14052 June 15, 2023 VIA EDGAR TRANSMISSION Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Erin Donahue Re: Astronics Corporation (Registrant) Astronics Advanced Electronic Systems Corp. (Additional Registrant) Astronics Test Systems Inc. (Additional Registrant) Astronics AeroSat Corporation (Additional Registrant) Astronics Connectivity Systems & Certification Corp. (Additional Registrant) Luminescent Systems, Inc. (Additional Registrant) Freedom Communication Technologies Inc. (Additional Registrant) PECO, Inc. (Additional Registrant) Diagnosys Holdings Inc. (Additional Registrant) Astronics Custom Control Concepts Inc. (Additional Registrant) Astronics DME LLC (Additional Registrant) Diagnosys Inc. (Additional Registrant) Astronics Air LLC (Additional Registrant) Astronics Air II LLC (Additional Registrant) Registration Statement on Form S-3 (File No. 333-272423) Ladies and Gentlemen: In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-3 (File No. 333-272423) (the “Registration Statement”) of Astronics Corporation, a New York corporation, Astronics Advanced Electronic Systems Corp., a Washington corporation, Astronics Test Systems Inc., a Delaware corporation, Astronics AeroSat Corporation, a New Hampshire corporation, Astronics Connectivity Systems & Certification Corp., an Illinois corporation, Luminescent Systems, Inc., a New York corporation, Freedom Communication Technologies Inc., a Delaware corporation, PECO, Inc., an Oregon corporation, Diagnosys Holdings Inc., a Delaware corporation, Astronics Custom Control Concepts Inc., a Washington corporation, Astronics DME LLC, a Florida limited liability company, Diagnosys Inc., a Delaware corporation, Astronics Air LLC, a New York limited liability company and Astronics Air II LLC, a New Hampshire limited liability company. We respectfully request that the Registration Statement become effective as of 4:30 p.m., Eastern Time, on June 20, 2023, or as soon thereafter as is practicable. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Hodgson Russ LLP, by calling Craig M. Fischer at (716) 848-1266. If you have any questions regarding the foregoing, please do not hesitate to contact Craig M. Fischer of Hodgson Russ LLP at (716) 848-1266. Thank you in advance for your consideration. Very truly yours, ASTRONICS CORPORATION By: /s/ David C. Burney Name: David C. Burney Title: Executive Vice President and Chief Financial Officer ASTRONICS ADVANCED ELECTRONICS SYSTEMS CORP. By: /s/ David C. Burney Name: David C. Burney Title: Secretary and Treasurer and Director ASTRONICS TEST SYSTEMS INC. By: /s/ David C. Burney Name: David C. Burney Title: Secretary and Treasurer and Director ASTRONICS AEROSAT CORPORATION By: /s/ David C. Burney Name: David C. Burney Title: Secretary and Treasurer and Director ASTRONICS CONNECTIVITY SYSTEMS & CERTIFICATION CORP. By: /s/ David C. Burney Name: David C. Burney Title: Secretary and Treasurer and Director LUMINESCENT SYSTEMS, INC. By: /s/ David C. Burney Name: David C. Burney Title: Secretary and Treasurer and Director FREEDOM COMMUNICATIONS TECHNOLOGIES INC. By: /s/ David C. Burney Name: David C. Burney Title: Secretary and Treasurer and Director PECO, INC. By: /s/ David C. Burney Name: David C. Burney Title: Secretary and Treasurer and Director DIAGNOSYS HOLDINGS INC. By: /s/ David C. Burney Name: David C. Burney Title: Secretary and Treasurer and Director ASTRONICS CUSTOM CONTROL CONCEPTS INC. By: /s/ David C. Burney Name: David C. Burney Title: Secretary and Treasurer and Director ASTRONICS DME LLC By Astronics Corporation, its sole member By: /s/ David C. Burney Name: David C. Burney Title: Executive Vice President and Chief Financial Officer DIAGNOSYS INC. By: /s/ David C. Burney Name: David C. Burney Title: Secretary and Treasurer and Director ASTRONICS AIR LLC By Astronics Corporation, its sole member By: /s/ David C. Burney Name: David C. Burney Title: Executive Vice President and Chief Financial Officer ASTRONICS AIR II LLC By Astronics Corporation, its sole member By: /s/ David C. Burney Name: David C. Burney Title: Executive Vice President and Chief Financial Officer cc: Julie M. Davis, Astronics Corporation Craig M. Fischer, Hodgson Russ LLP