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SEC Company Response from INNOVATIVE SOLUTIONS & SUPPORT INC (ISSC) (CIK 0000836690) (IA) — May 15, 2007

INNOVATIVE SOLUTIONS & SUPPORT INC (ISSC) (CIK 0000836690)
Date: May 15, 2007 · CIK: 0000836690 · Accession: 0001104659-07-039818

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File numbers found in text: 333-140018

Date
May 15, 2007
Author
Stephen M. Leitzell, Esq.
Form
CORRESP
Company
INNOVATIVE SOLUTIONS & SUPPORT INC (ISSC) (CIK 0000836690)

Letter

RE: Innovative Solutions and Support, Inc.

May 15, 2007

VIA EDGAR AND OVERNIGHT DELIVERY

United States Securities and Exchange Commission

100 F Street NE

Washington, D.C. 20549

Attn: Barbara C. Jacobs and Hugh Fuller

Amendment No. 3 to the Registration Statement on Form S-3

File No. 333-140018

Ladies and Gentlemen:

Innovative Solutions and Support, Inc. (the “Company”) has today filed with the Securities and Exchange Commission (the “Commission”) Amendment No. 3 (“Amendment No. 3”) to its Registration Statement on Form S-3 (Registration No. 333-140018). On behalf of the Company, we respond to the comment raised by the staff of the Commission in a telephone call from Mr. Hugh Fuller to the undersigned by including an updated legal opinion of Dechert LLP, dated May 11, 2007, and providing that the Amendment No. 3 incorporates by reference the Company’s Form 10-Q for the three months ended March 31, 2007, which was filed by the Company on May 10, 2007.

If you have any questions, please feel free to contact Henry N. Nassau at 215.994.2138 or the undersigned at 215.994.2621. Thank you for your cooperation and attention to this matter.

Sincerely,
Stephen M. Leitzell, Esq.

Show Raw Text
CORRESP
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filename1.htm

May 15, 2007

VIA EDGAR AND OVERNIGHT DELIVERY

United States Securities
and Exchange Commission

100 F Street NE

Washington, D.C.  20549

Attn:  Barbara C. Jacobs and Hugh Fuller

RE:                            Innovative
Solutions and Support, Inc.

Amendment No. 3 to the Registration Statement on Form S-3

File No. 333-140018

Ladies and Gentlemen:

Innovative Solutions and Support, Inc. (the “Company”)
has today filed with the Securities and Exchange Commission (the “Commission”)
Amendment No. 3 (“Amendment No. 3”) to its Registration Statement
on Form S-3 (Registration No. 333-140018).  On behalf of
the Company, we respond to the comment raised by the staff of the Commission in
a telephone call from Mr. Hugh Fuller to the undersigned by including an
updated legal opinion of Dechert LLP, dated May 11, 2007, and providing
that the Amendment No. 3 incorporates by reference the Company’s
Form 10-Q for the three months ended March 31, 2007, which was filed
by the Company on May 10, 2007.

If you have any questions, please feel free to contact
Henry N. Nassau at 215.994.2138 or the undersigned at 215.994.2621.  Thank you for your cooperation and attention
to this matter.

  Sincerely,

  Stephen M. Leitzell, Esq.

cc:         Geoffrey S. M. Hedrick

James J. Reilly

Henry N. Nassau, Esq.

 2