SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

Mail Stop 6010
May 30, 2008

VIA U.S. MAIL AND FAX (407) 578-7731

Mr. Harold D. Castle
Chief Financial Officer
The LGL Group, Inc.
2525 Shader Road
Orlando, Florida 32804

 Re: The LGL Group, Inc.
  Form 10-K for the year ended December 31, 2007
  Filed May 13, 2008
  File No. 001-00106

Dear Mr. Castle:

We have reviewed your filings and have th e following comments.  Where indicated, we
think you should revise your future filings in re sponse to these comments.  If you disagree, we
will consider your explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your explanati on.  In some of our comments,
we may ask you to provide us with informati on so we may better unders tand your disclosure.
After reviewing this information, we may raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filing.  We look forward to working with you in these respects.  We welcome any questions
you may have about our comments or any other aspect of our review.  Feel fr ee to call us at the
telephone numbers listed at th e end of this  letter.

Mr. Harold D. Castle
The LGL Group, Inc.
May 30, 2008 Page 2
Form 10-K for the Fiscal Year Ended December 31, 2007

Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page
17

Liquidity and Capital Resources, page 19

1. Revise future filings to defi ne the financial ratios and mini mum net worth levels required
in your financial covenants.

Critical Accounting Policies, Revenue Recognition, page 22

2. We note that you include revenue recogniti on as one of your critical accounting
estimates. Your discussion herein does not di scuss the nature of a ny estimates regarding
the company’s revenue recogniti on. The disclosure merely rep eats the policies from your
significant accounting policies footnote wit hout elaboration. Your disclosure should
supplement, not duplicate, the description of your accounting policies that are already
disclosed in the notes to the financial st atements. Your discussion should present your
analysis of the uncertainties involved in applying accounting principles, specifically address why your accounting estimates bear th e risk of change, how you arrived at the
estimate, whether that estimate is reasonably like ly to change, etc. Please revise in future
filings.  We refer you to SEC Release No. 33-8350, Commission Guidance Regarding
Management’s Discussion and Analysis of Financial Condition and Results of
Operations.

Financial Statements, page 44

Note 1. Accounting and Reporting Policies, page 49

Revenue Recognition, page 51

3. We note that you recognize revenue upon shipment. We also note your disclosure on pages 2 and 8 that your products are “cus tom designed highly-engineered electric
components.” Given the customization of your products please explain any customer
acceptance provisions included in your sales agreements. For example, tell us if your customers have the right to test the equipm ent prior to acceptance. In addition, tell us
about any obligations you have, if any, subseq uent to shipment. Please include a clear
discussion of the agreements, which would indicate that the revenue  recognition criteria
outlined in SAB 104 has been met.

4. In this regard, please explai n your return policy, including any warranties provided to
your customers and how they impact your revenue recognition. We note the disclosure on page 17, regarding “yield losses” and increa sed “rework costs” at  your Orlando, facility.

Mr. Harold D. Castle
The LGL Group, Inc.
May 30, 2008 Page 3
Explain what these costs involve and revise your disclosure in future filings to discuss in
greater detail.

5. We note your use of distributors to sell your pr oducts. Please descri be the terms of your
arrangements with distributors, including payment, price protection, return, exchange,
and other significant terms.  Disclose wh en sales through these distributors are
recognized, if different from your usual policy of recognizing revenue upon product
shipment. If you recognize revenue on shipment  of product to distributors, explain why
you believe this practice is appr opriate.  Refer to the guida nce in paragraph 6 of SFAS 48
in your response.

Note 2. Restatement of Consolidat ed Financial Statements, page 56

Consolidated Balance Sheet Adjustments, page 58

6. We note the $451,000 in accrued compensation expe nse as one of your reclassifications
for the December 31, 2006 balance sheet. Please e xplain the nature of this reclassification
and the error to which it relates.

7. Your disclosure on page 61 indi cates that you incorrectly clas sified the net carrying value
of select Lynch Systems assets as assets held for sale duri ng the three months ended June
30, 2007, instead of asset held for use. We note you subsequently reclassified the net
carrying value and related accumulated deprec ation on your balance sheet. Please explain
how you adjusted the related depreciation expense  on your statement of operations for
June 30, 2007 and subsequent quarters and quantify the amounts.

 As appropriate, please respond to these comm ents within 10 business days or tell us
when you will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested information.  De tailed letters greatly f acilitate our review.
Please understand that we may have additional co mments after reviewing your responses to our
comments.

  We urge all persons who are responsible fo r the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.

 In connection with responding to our comme nts, please provide, in writing, a statement
from the company acknowledging that:

Mr. Harold D. Castle
The LGL Group, Inc.
May 30, 2008 Page 4
‚ the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

‚ staff comments or changes to disclosure in re sponse to staff comments do not foreclose the
Commission from taking any action with respect to the filing; and

‚ the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.
You may contact Julie Sherma n, Staff Accountant, at (202)  551-3640, or me at (202)
551-3554 if you have questions regard ing these comments.  In this regard, do not hesitate to
contact Martin James, the Senior Assi stant Chief Accountant, at (202) 551-3671.

        S i n c e r e l y ,

        A n g e l a  C r a n e
        B r a n c h  C h i e f