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SEC Comment Letter for SUNation Energy, Inc. (SUNE) (CIK 0000022701) (SUNE) — Oct 29, 2010

SUNation Energy, Inc. (SUNE) (CIK 0000022701)
Date: Oct. 29, 2010 · CIK: 0000022701 · Accession: 0000000000-10-064220

AI Filing Summary & Sentiment

File numbers found in text: 001-31588

Referenced dates: October 1, 2010

Date
October 29, 2010
Author
/s/Larry Spirgel
Form
UPLOAD
Company
SUNation Energy, Inc. (SUNE) (CIK 0000022701)

Letter

October 29, 2010 Mr. Jeffrey K. Berg President and Chief Executive Officer Communications Systems, Inc. 10900 Red Circle Drive Minnetonka, MN 55343 Re: Communications Systems, Inc. Form 10-K for fiscal year ended December 31, 2009 Filed March 18, 2010 Form 10-Q for period ended June 30, 2010 Filed August 10, 2010 File No. 001-31588

Dear Mr. Berg:

We have reviewed your response letter da ted October 19, 2010 and have the following comment. Please respond to this letter within ten business da ys by amending your filing or by advising us when you will provide the requested response.

Form 10-K for fiscal year ended December 31, 2009

Item 9A (T): Controls and Procedures, page 45

1. We note your response to comments four and fi ve from our letter dated October 1, 2010. Please revise your conclusion to clearly provide Management's assessment of the effectiveness of your internal control over financial reporting as of December 31, 2009, including a statement as to whether or not internal control over fi nancial reporting was effective. Additionally , please revise to clearly disclose an y change in your internal control over financial reporting that occu rred during the last fiscal quarter of 2009 that has materially affected, or is reasonably likely to materially affect, your internal control over financial reporting.

Jeffrey K. Berg Communications Systems, Inc. October 29, 2010 Page 2

You may contact Christine Adams, Senior Staff Accountant, at ( 202) 551-3363, or Carlos Pacho, Senior Assistant Chief Accountant, at (202) 551-3835 if you have questions regarding comments on the financial statements and rela ted matters. You may contact Reid Hooper, Attorney-Adviser, at (202) 551-3359, Robert Bartel mes, Senior Financial Analyst, at (202) 551- 3354, or me, at (202) 551-3810 w ith any other questions.

Sincerely,
/s/Larry Spirgel
A s s i s t a n t D i r e c t o r

Show Raw Text
October 29, 2010

  Mr. Jeffrey K. Berg President and Chief Executive Officer Communications Systems, Inc.  10900 Red Circle Drive Minnetonka, MN 55343
Re:  Communications Systems, Inc.
  Form 10-K for fiscal year ended December 31, 2009
Filed March 18, 2010
Form 10-Q for period ended June 30, 2010 Filed August 10, 2010 File No. 001-31588

Dear Mr. Berg:

 We have reviewed your response letter da ted October 19, 2010 and have the following
comment.  Please respond to this  letter within ten business da ys by amending your filing or by
advising us when you will provide the requested response.

Form 10-K for fiscal year  ended December 31, 2009

Item 9A (T):  Controls and Procedures, page 45

1. We note your response to comments four and fi ve from our letter dated October 1, 2010.
Please revise your conclusion to clearly provide Management's assessment of the
effectiveness of your internal control over financial reporting as of December 31, 2009,
including a statement as to whether or not internal control over fi nancial reporting was
effective.   Additionally , please revise to clearly disclose an y change in your internal control
over financial reporting that occu rred during the last fiscal quarter of 2009 that has materially
affected, or is reasonably likely to materially  affect, your internal control over financial
reporting.

Jeffrey K. Berg Communications Systems, Inc.  October 29, 2010 Page 2

  You may contact Christine Adams, Senior Staff Accountant, at ( 202) 551-3363, or Carlos
Pacho, Senior Assistant Chief Accountant, at (202) 551-3835 if you have questions regarding
comments on the financial statements and rela ted matters.  You may contact Reid Hooper,
Attorney-Adviser, at (202) 551-3359, Robert Bartel mes, Senior Financial Analyst, at (202) 551-
3354, or me, at (202) 551-3810 w ith any other questions.

Sincerely,

/s/Larry Spirgel
        A s s i s t a n t  D i r e c t o r