SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

 June 23, 2011
 Via E-mail

Mr. R. LaDuane Clifton Chief Accounting 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, 2010   Filed March 24, 2011
Form 10-Q for the period ended March 31, 2011 Filed May 16, 2011  File No. 001-00106
Dear Mr. Clifton:

We have reviewed your filings and have the following comments.  In some of our comments,
we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

R. LaDuane Clifton
The LGL Group, Inc. June 23, 2011 Page 2
 Form 10-K for the Year ended December 31, 2010

 Financial Statements, page 41

 A. Accounting and Reporting Policies, page 45

 Revenue Recognition, page 48

 1. Please expand future filings to describe your re venue recognition policy in greater detail.
For example, we note from your disclosure on page 4 that you sell your products through
a variety of channels and agen ts, to the extent that your re venue recognition policy differs
among the various marketing venues, please pr ovide details as to how those policies
differ. Also, we see that you se ll to a number of different re gions of the world; if your
policies vary in different parts of the world those differences should also be discussed.
Please provide details of discounts, return po licies, post shipment obligations, customer
acceptance, warranties, credits, rebates, a nd price protection or similar privileges and
how these impact revenue recognition.  Please provide us with your proposed revised
disclosure as part  of your response.
 2. Please revise future filings to provide th e disclosures required by FASB ASC 460-10-50-
8 (formerly paragraph 14 of FIN 45), as it rela tes to your product warranties.  Please also
discuss any changes with regards to the warr anties offered to customers during the year
and any related changes in your accrual or accounting. Pl ease provide us with your
proposed revised disclosure as part of your response.

     We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:   the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
  staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

R. LaDuane Clifton
The LGL Group, Inc. June 23, 2011 Page 3
  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.

  You may contact Julie Sherma n, Staff Accountant, at (202)  551-3640 or me at (202) 551-
3212 if you have any questions regarding these co mments. In this regard, do not hesitate to
contact Martin James, Senior Assist ant Chief Accountant, at (202) 551-3671.
           S i n c e r e l y ,

 /s/ Jeffrey Jaramillo
         Jeffrey Jaramillo         A c c o u n t i n g  B r a n c h  C h i e f