SecProbe.io

Mail Stop 3720

July 25, 2017

Fred Kornberg
Chief Executive Officer
Comtech Telecommunications Corp.
68 South Service Road, Suite 230
Melville, NY

Re: Comtech Telecommunications Corp.
 Form 10 -K for Fiscal Year Ended July 31, 2016
Filed October 6, 2016
File No. 000 -07928

Dear Mr. Kornberg :

We have reviewed your filing  and have the following comment .  In our comment , we ask
you to provide us with information so we may better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comment applies  to your facts and circumstances , please tell us why in your response.

After reviewing your response to this comment , we may have additional comments.

Notes to Consolidated Financial Statements

(2) Acquisition, page F -16

1. We note that in the acquisition of TCS you alloca ted 66% of the purchase price to
customer relationships and backlog.   Also we note that you estimated the useful life of
this intangible to be 21 years.   Please tell us the specific factors you considered in
concluding that an estimated useful lives of 21 years is appropriate for the customer
relationships intangible asset.

Fred Kornberg
Comtech Telecommunications Corp.
July 25, 2017
Page 2

 We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action  by the staff.

You may contact Ivette Leon, Assistant Chief Accountant,  at (202) 551 -3351 or Carlos
Pacho, Senior Assistant Chief Accountant, at (202) 551 -3835  if you have questions regarding
comments on the financial statements and related matters.  Please contact William Mastrianna,
Attorney -Adviser,  at (202) 551 -3778 or me at (202) 551 -3810  with any other questions.

Sincerely,

 /s/ Carlos Pacho for

 Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications