SecProbe.io

June 12 , 2014

Via E -Mail
Robert A. Berman
Chief Executive Officer
CopyTele, Inc.
900 Walt Whitman Road
Melville, New York 11747

Re: CopyTele, Inc.
 Preliminary Proxy  Statement on Schedule 14 A
Filed on June 3, 2014
File No. 000-11254

Dear Mr. Berman :

We have reviewed your filing an d 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 ten business days by amending your filing, 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  circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Proposal 4

Name Change Proposal, page 42

1. Please tell us, and e xpand your  disclosure to reference , what in your bylaws, articles of
incorporation or other governing documents permits you to change your corporate name
to another name to be selected by you at a later dat e without informing shareholders of
the new name .  In your response letter, explain how the authority the board seeks with
respect to a future selection of a corporate name is consistent wi th Delaware law and the
proxy rules.

We urge all persons who are  responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are

Robert A. Berman
CopyTele, Inc.
June 12, 2014
Page 2

 in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written 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

 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.

Please contact Ji Kim, Attorney -Advisor, at (202) 551 -3579  or, in her absence, the
undersigned at (202) 551 -3457 with any questions.

Sincerely,

 /s/ Maryse Mills -Apenteng

Maryse Mills -Apenteng
Special Counsel