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Correspondence 0000950142-24-001974 from COMTECH TELECOMMUNICATIONS CORP /DE/ (CMTL)

COMTECH TELECOMMUNICATIONS CORP /DE/
Date: July 19, 2024 · CIK: 0000023197 · Accession: 0000950142-24-001974

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File numbers found in text: 333-280839

Date
July 19, 2024
Author
/s/ Michael A. Bondi
Form
CORRESP
Company
COMTECH TELECOMMUNICATIONS CORP /DE/

Letter

COMTECH TELECOMMUNICATIONS CORP.

305 N 54th Street

Chandler, Arizona 85226

July 19, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Bradley Ecker

Comtech Telecommunications Corp.

Registration Statement on Form S-1

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, we hereby request that the effective date of the above-captioned Registration Statement on Form S-1, file No. 333-280839 (the “Registration Statement”), of Comtech Telecommunications Corp. (the “Company”) be accelerated to July 23, 2024 at 4:00 p.m., Eastern Time, or as soon thereafter as may be practicable.

We understand that the Staff will consider this request as confirmation by the Company of its awareness of its responsibilities under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Raphael M. Russo of Paul, Weiss, Rifkind, Wharton & Garrison LLP at (212) 373-3309.

* * *

Very truly yours,
By:
/s/ Michael A. Bondi

Show Raw Text
CORRESP
1
filename1.htm

COMTECH TELECOMMUNICATIONS CORP.

305 N 54th Street

Chandler, Arizona 85226

July 19, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:     Bradley Ecker

Comtech Telecommunications
Corp.

Registration Statement on Form S-1

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended, we hereby request that the effective date of the above-captioned Registration Statement on Form S-1, file No.
333-280839 (the “Registration Statement”), of Comtech Telecommunications Corp. (the “Company”) be accelerated
to July 23, 2024 at 4:00 p.m., Eastern Time, or as soon thereafter as may be practicable.

We understand that the Staff will consider this
request as confirmation by the Company of its awareness of its responsibilities under the federal securities laws as they relate to the
issuance of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Raphael
M. Russo of Paul, Weiss, Rifkind, Wharton & Garrison LLP at (212) 373-3309.

*	*	*

    Very truly yours,

    By:
    /s/ Michael A. Bondi

    Name:
    Michael A. Bondi

    Title:
    Chief Financial Officer