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SEC Company Response from COMTECH TELECOMMUNICATIONS (CMTL) — Apr 8, 2010

COMTECH TELECOMMUNICATIONS CORP /DE/ (CMTL) (CIK 0000023197)
Date: April 8, 2010 · CIK: 0000023197 · Accession: 0001193125-10-079488

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Confidence
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Referenced dates: February 2, 2010, March 9, 2010

Date
April 8, 2010
Author
/s/ Robert Cantone
Form
CORRESP
Company
COMTECH TELECOMMUNICATIONS CORP /DE/ (CMTL) (CIK 0000023197)

Letter

United States Securities and Exchange Commission Division of Corporation Finance RE: Comtech Telecommunications Corp. Form 10-K for the year ended July 31, 2009 (the “Form 10-K”) Filed September 23, 2009 File No. 0-07928

Dear Ms. Krebs and Ms Plowgian,

On behalf of Comtech Telecommunications Corp. (the “Company”), this is to confirm that, pursuant to the telephone discussion on April 6, 2010 among representatives of, and advisors to, the Company and you regarding your letter dated February 2, 2010 offering comments on the above-referenced filing and the Company’s response letter dated March 9, 2010, the Company will provide you a supplemental response letter on or before May 4, 2010 addressing the matters covered in that telephone discussion.

Very truly yours,
/s/ Robert Cantone

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CORRESP
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filename1.htm

Correspondence

 Proskauer Rose LLP 1585 Broadway New York, NY 10036-8299

Robert A. Cantone

 Member of the Firm

 d
212.969.3235

 f 212.969.2900

 rcantone@proskauer.com

 www.proskauer.com

 April 8, 2010

 Kathleen Krebs, Esq., Special Counsel

 Jessica Plowgian, Esq., Attorney-Advisor

 United
States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

RE:
Comtech Telecommunications Corp.

 Form 10-K for the year ended July 31, 2009 (the “Form 10-K”)

 Filed September 23, 2009

 File No. 0-07928

 Dear Ms. Krebs and Ms Plowgian,

 On behalf of Comtech Telecommunications Corp. (the “Company”), this is to confirm
that, pursuant to the telephone discussion on April 6, 2010 among representatives of, and advisors to, the Company and you regarding your letter dated February 2, 2010 offering comments on the above-referenced filing and the Company’s
response letter dated March 9, 2010, the Company will provide you a supplemental response letter on or before May 4, 2010 addressing the matters covered in that telephone discussion.

Very truly yours,

/s/ Robert Cantone

Robert A. Cantone

cc:
Michael D. Porcelain

 Senior
Vice President, Chief Financial Officer

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