SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

 August 2, 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 response filed July 22, 2011 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 circ umstances or do not believe an amendment is
appropriate, please tell us why 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. August 2, 2011 Page 2

Form 10-K for the Year ended December 31, 2010

 Item 11. Executive Compensation, page 30

 1. Please tell us why page 31 of this filing and page 14 of your definitive proxy statement
filed July 7, 2011 disclose different base  salaries under Mr. Anderson’s current
employment agreement.
 Financial Statements, page 41

 A. Accounting and Reporting Policies, page 45

 Revenue Recognition, page 48

 2. We note from your response to our prior co mment 1 that you offer a limited right of
return and authorized price protection pr ovisions in your agreements with certain
distributors.  To help us better understa nd your revenue recognition policy for those
arrangements where you provide price pr otection provisions, please address the
following:

 Provide us with the terms of your price protection provisions.
 Tell us, for each year presented in your financial statements, the amount of revenue
recognized for transactions that included these pri ce protection provisions.
 Provide a detailed explanation as to how you meet the fixed or determinable sales
price criteria prescr ibed by SAB Topic 13A.4
 3. Additionally, we note from your response to  our prior comment 1 that you recognize
revenue when, among other met conditions, the “seller’s price to the buyer is
substantially
 fixed or determinable at the date of  sales.”  Please address the following:

 Tell us what you mean by “substantially fixe d” and provide us an example of an
arrangement with a substantially fixed or de terminable price as compared to one with
a fixed or determinable price.
 Explain to us in detail how this “substanti ally fixed or determinable” condition meets
the criteria outlined in SAB Topic 13A.4.
 Quantify for us the amount of revenue recognized for each transaction where you
determined that the seller’s price to the buyer was substant ially fixed or determinable
at the date of sale.
 For each fiscal year presented, tell us the amount of revenue you recognized from
transactions with substantially fixed or determinable prices.

R. LaDuane Clifton
The LGL Group, Inc. August 2, 2011 Page 3
 4. Also, we note from your proposed disclosure  in response to prior comment 1 that you
recognize revenue when, among other met conditions, the “seller does not have
significant
 obligations for future performance to di rectly bring about resale of the product
by the buyer.”  Please explain to us in detail how this condition meets the criteria outlined
in SAB Topic 13A.3.  Describe to us the oblig ations that had not been performed at the
time of revenue recognition and explain w hy you believe these obligations are either
inconsequential or perfunctory  performance obligations.

 You may contact Julie Sherman, Staff Account ant, at (202) 551-3640 or Jeff Jaramillo,
Accounting Branch Chief, at (202) 551-3212 if  you have any questions regarding comments on
the financial statements and related matters.  Plea se contact Allicia Lam, Staff Attorney, at (202)
551-3316 or Geoffrey Kruczek, Reviewing Attorn ey, at (202) 551-3641 if you have questions on
any other comments.            S i n c e r e l y ,
 /s/ Martin James

       M a r t i n  J a m e s         Senior Assistant Chief Accountant