SEC Comment Letter for COMTECH TELECOMMUNICATIONS (CMTL) — Dec 17, 2015
COMTECH TELECOMMUNICATIONS CORP /DE/ (CMTL) (CIK 0000023197)
Date: Dec. 17, 2015 · CIK: 0000023197 · Accession: 0000000000-15-058285
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-208560
Letter
Mail Stop 3720 December 16, 2015 Dr. Stanton Sloane Comtech Telecommunications Corp. 68 South Service Road, Suite 230 Melville, NY 11747
Re: Comtech Telecommunications Corp. Registration Statement on Form S-3 Filed December 15, 2015 File No. 333-208560
Dear Dr. Sloane :
This is to advise you that we have not reviewed and will not review your registration statement .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that:
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h respect to the filing;
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and
the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Dr. Stanton D. Sloane Comtech Telecommunications Corp. December 16, 2015 Page 2
Please refer to Rules 460 and 4 61 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and th e Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities .
Please contact Emily C. Drazan, Staff Attorney at (202) 551 -3208 with any questions.
Sincerely,
/s/ Celeste M. Murphy for
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Mail Stop 3720 December 16, 2015 Dr. Stanton Sloane Comtech Telecommunications Corp. 68 South Service Road, Suite 230 Melville, NY 11747 Re: Comtech Telecommunications Corp. Registration Statement on Form S-3 Filed December 15, 2015 File No. 333-208560 Dear Dr. Sloane : This is to advise you that we have not reviewed and will not review your registration statement . We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In the event you request acceleration of the effective date of the pending regist ration statement , please provide a written statement from the company acknowledging that: should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action wit h respect to the filing; the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in th e filing; and the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Dr. Stanton D. Sloane Comtech Telecommunications Corp. December 16, 2015 Page 2 Please refer to Rules 460 and 4 61 regarding requests for acceleration . We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and th e Securities Exchange Act of 1934 as they relate to the proposed public offering of the registered securities . Please contact Emily C. Drazan, Staff Attorney at (202) 551 -3208 with any questions. Sincerely, /s/ Celeste M. Murphy for Larry Spirgel Assistant Director AD Office 11 – Telecommunications