SEC Comment Letter for COMTECH TELECOMMUNICATIONS (CMTL) — Mar 9, 2020
COMTECH TELECOMMUNICATIONS CORP /DE/ (CMTL) (CIK 0000023197)
Date: March 9, 2020 · CIK: 0000023197 · Accession: 0000000000-20-002076
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File numbers found in text: 333-236840
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March 6, 2020
Michael D. Porcelain
Senior Vice President and Chief Operating Officer
Comtech Telecommunications Corp./DE/
68 South Service Road, Suite 230
Melville, NY 11747
Re:Comtech Telecommunications Corp./DE
Registration Statement on Form S-4
Filed March 2, 2020
File No. 333-236840
Dear Mr. Porcelain:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
Please contact Asia Timmons-Pierce at 202-551-3754 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing