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SEC Company Response from COMTECH TELECOMMUNICATIONS (CMTL) — Feb 12, 2010

COMTECH TELECOMMUNICATIONS CORP /DE/ (CMTL) (CIK 0000023197)
Date: Feb. 12, 2010 · CIK: 0000023197 · Accession: 0001193125-10-030509

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Referenced dates: February 2, 2010

Date
February 11, 2010
Author
Assistant Director
Form
CORRESP
Company
COMTECH TELECOMMUNICATIONS CORP /DE/ (CMTL) (CIK 0000023197)

Letter

VIA EDGAR Securities and Exchange Commission Form 10-K for the year ended July 31, 2009 Filed September 23, 2009 File No. 0-07928

RE: Comtech Telecommunications Corp.

Dear Mr. Spirgel:

This will acknowledge receipt of your letter dated February 2, 2010 to the undersigned, the Senior Vice President and Chief Financial Officer of the above-referenced registrant, providing comments on the registrant’s Annual Report on Form 10-K referred to above. Your letter was received at the registrant’s offices by mail on February 8. I did not receive the fax transmission of the letter, since the fax number your office used is not correct. Please note that the correct fax number is 631.962.7203.

Your letter requests the registrant’s response to the comments within 10 business days (February 17, 2010). The registrant’s financial reporting group is currently preparing the registrant’s Quarterly Report on Form 10-Q for the fiscal quarter ended January 31, 2010, and anticipates that it will need additional time to respond appropriately to your comment letter. As our counsel, Robert Cantone, discussed with Staff Accountant Kathryn Jacobson, on February 9, the registrant proposes to provide its response to the comment letter no later than March 9, 2010.

We thank you for your courtesy in this matter.

Very truly yours,
/s/ Michael D. Porcelain

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CORRESP
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Correspondence

 February 11, 2010

 VIA EDGAR

 Mr. Larry Spirgel

 Assistant Director

 Securities and Exchange Commission

 Washington, D.C. 20549

RE:
Comtech Telecommunications Corp.

 Form 10-K for the year ended July 31, 2009

 Filed
September 23, 2009

 File No. 0-07928

 Dear Mr. Spirgel:

 This will acknowledge
receipt of your letter dated February 2, 2010 to the undersigned, the Senior Vice President and Chief Financial Officer of the above-referenced registrant, providing comments on the registrant’s Annual Report on Form 10-K referred to
above. Your letter was received at the registrant’s offices by mail on February 8. I did not receive the fax transmission of the letter, since the fax number your office used is not correct. Please note that the correct fax number is
631.962.7203.

 Your letter requests the registrant’s response to the comments within 10 business days (February 17, 2010). The
registrant’s financial reporting group is currently preparing the registrant’s Quarterly Report on Form 10-Q for the fiscal quarter ended January 31, 2010, and anticipates that it will need additional time to respond appropriately to
your comment letter. As our counsel, Robert Cantone, discussed with Staff Accountant Kathryn Jacobson, on February 9, the registrant proposes to provide its response to the comment letter no later than March 9, 2010.

 We thank you for your courtesy in this matter.

Very truly yours,

 /s/ Michael D. Porcelain

Michael D. Porcelain

Senior Vice President and Chief Financial Officer