SecProbe.io

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Mail Stop 7010

November 29, 2005

via U.S. mail and facsimile

Marty R. Kittrell
Chief Financial Officer
Andrew Corporation
10500 W. 153rd Street
Orland Park, Illinois  60462

	Re:	Andrew Corporation
		Form 10-K for the Fiscal Year Ended September 30, 2004
		Filed December 13, 2004
Forms 10-Q for the Fiscal Quarters Ended December 31, 2004, March
31,
2005 and June 30, 2005
		File No. 0-21682

Dear Mr. Kittrell:

      We have reviewed your response letter dated November 14,
2005
and considered your positions presented during our conference call
on
October 14, 2005.  We have the following additional comment.

Form 10-K for the Fiscal Year Ended September 30, 2004

1.  Summary of Significant Accounting Policies, Revenue
Recognition,
page 32

1. We note your response to comment 2 in your letter dated
November
14, 2005.  Specifically, you refer to Article 1, Section 6.1,
Invoices and Payment of the General Purchase Agreement as the
clause
in the contract that prohibits you from recognizing PSAP
integration
revenue until completion of certification services.  Your response
letter also refers to Addendum 5 to the GPA as the change to the
contract that separated PSAP integration and certification
services
such that revenue recognition for PSAP integration was no longer
prohibited prior to completion of certification services under US
GAAP.

However, we note that a prior addendum to the GPA, executed prior
to
the acquisition of Allen, appears to have amended the GPA in a
manner
similar to Addendum 5.  Thus, based on your line of reasoning, it
would appear that prior to the acquisition of
Allen, PSAP integration revenue should no longer have been
deferred
until the completion of certification services.

Secondly, you further support your deferral of PSAP integration
revenue by referencing Article 1, Section 4.1 of the GPA,
Termination
and Deferral of Orders.  You state that this section addresses
your
rights to receive payment for completed PSAP integration services,
in
case of termination prior to completion of certification services.
Section 4.1 appears to apply to your customer`s ability to cancel
an
order only with regards to equipment and not any subsequent
services,
such as PSAP integration and certification, which would be
provided
once the equipment is shipped.  Therefore, it does not appear that
your customer has the right/ability to cancel/terminate the PSAP
integration and certification services once the equipment is
shipped.
Thus, it is unclear to us how Article 1, Section 4.1 of the GPA is
relevant.

Finally, we note that Article 1, Section 4.1 of the GPA has not
been
amended by Addendums 1-5.  Thus, it is unclear how the changes in
Addendum 5 affected the termination provisions in your agreement
such
that you were no longer precluded from recognizing PSAP
integration
services revenue prior to the completion of certification
services.

Based on the above factors noted,  your deferral of PSAP
integration
services revenue until completion of certification services until
the
fourth quarter of 2004 does not appear appropriate under US GAAP.

*    *    *    *

      You may contact Tracey Houser at (202) 551-3736, or me at
(202)
551-3255, if you have questions regarding comments on the
financial
statements and related matters.

Sincerely,

Nili Shah
Accounting Branch Chief

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Marty R. Kittrell
Andrew Corporation
November 29, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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