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Letter to the SEC

Via Electronic Submission (Correspondence)

August 13, 2007

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Mergers and Acquisitions

100 F Street, N.E.

Washington, D.C. 20549

Attention: Nicholas P. Panos, Special Counsel

    Re:

    Harris Corporation

Schedule TO-I, Filed July 19, 2007, SEC File No. 005-37049

Dear Mr. Panos:

     On behalf of our client Harris Corporation (“Harris”), we hereby submit our response to the
July 30, 2007 oral comments of the Staff of the Division of Corporation Finance (the “Staff”) of
the Securities and Exchange Commission (the “Commission”) regarding the Schedule TO-I, filed by
Harris on July 19, 2007, SEC File No. 005-37049 (the “Schedule TO-I”), provided in conversations
between Mr. Panos and Mr. Colao, Ms. Green and Ms. MacCullough of our firm. Pursuant to your oral
comments, you requested that Harris confirm that the 3.5% Convertible Debentures due 2022 (the
“Convertible Debentures”) issued by Harris on August 26, 2002 that are the subject of the
referenced Issuer Tender Offer, are not and have not been since the date of their issuance subject
to registration under Section 15(d) of the Securities Exchange Act of 1934, as amended (the
“Exchange Act”).

     On behalf of Harris, we hereby confirm that the Convertible Debentures, are not and have not
been since the date of their issuance subject to registration under Section 15(d) of the Exchange
Act. The Convertible Debentures were originally issued on August 26, 2002 in a private placement.
The table below sets forth the number of persons that were “holders of

Atlanta • Bethesda • Boston • Chicago • Fort Lauderdale • Jacksonville • Los Angeles

Miami • New York • Northern Virginia • Orlando • Portland • San Francisco

Tallahassee • Tampa • Washington, D.C. • West Palm Beach

Division of Corporation Finance

Office of Mergers and Acquisitions

Attention: Nicholas P. Panos

August 13, 2007

Page 2

record”, as defined in Rule 12g5-1 of the Exchange Act, of the Convertible Debentures at the
end of each of Harris’ fiscal years since the Convertible Debentures were issued.

    Fiscal Year Ended

    Holders of Record

    June 27, 2003

    47

    July 2, 2004

    51

    July 1, 2005

    34

    June 30, 2006

    29

    June 29, 2007

    27

     In addition, at the time we commenced the Issuer Tender Offer there were 28 holders of record
of the Convertible Debentures.

     If you have any additional questions regarding the Schedule TO-I, please feel free to call the
undersigned at 904-798-5488.

    Holland & Knight, LLP

    /s/ Ivan A. Colao

    Ivan A. Colao

    cc:

    Scott T. Mikuen, Vice President,

Associate General Counsel and

Corporate Secretary