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
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CORRESP
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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