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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: 0001104659-07-039877

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File numbers found in text: 333-140018

Date
May 15, 2007
Author
Chief Financial
Form
CORRESP
Company
INNOVATIVE SOLUTIONS & SUPPORT INC (ISSC) (CIK 0000836690)

Letter

INNOVATIVE SOLUTIONS AND SUPPORT, INC.

720 Pennsylvania Drive

Exton, Pennsylvania 19341

Telephone:

(610) 646-9800

Facsimile:

(610) 646-0150

May 15, 2007

VIA EDGAR

United States Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: Innovative Solutions and Support, Inc.

Registration Statement on Form S-3

Registration No. 333-140018

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the undersigned Registrant hereby requests that the effectiveness of the above-captioned Registration Statement be accelerated so that it will become effective as of 4:00 pm on May 18, 2007, or as soon thereafter as practicable.

The Registrant acknowledges that:

1. should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, the Commission is not foreclosed from taking any action with respect to the Registration Statement;

2. the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant of its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

3. the Registrant may not assert the declaration of effectiveness of the Registration Statement by the Commission or the staff as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
INNOVATIVE
SOLUTIONS AND SUPPORT,

Show Raw Text
CORRESP
1
filename1.htm

INNOVATIVE SOLUTIONS AND SUPPORT,
INC.

720 Pennsylvania Drive

Exton, Pennsylvania 19341

  Telephone:

  (610) 646-9800

  Facsimile:

  (610) 646-0150

May 15, 2007

VIA EDGAR

United States Securities
and Exchange Commission

100 F Street, NE

Washington, D.C.  20549

Re:                               Innovative Solutions and Support, Inc.

Registration Statement on Form S-3

Registration No. 333-140018

Ladies and Gentlemen:

Pursuant to Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended,
the undersigned Registrant hereby requests that the effectiveness of the
above-captioned Registration Statement be accelerated so that it will become
effective as of 4:00 pm on May 18, 2007, or as soon thereafter as practicable.

The Registrant acknowledges
that:

1.        should the Commission or the staff,
acting pursuant to delegated authority, declare the Registration Statement
effective, the Commission is not foreclosed from taking any action with respect
to the Registration Statement;

2.        the action of the Commission or the
staff, acting pursuant to delegated authority, in declaring the Registration
Statement effective, does not relieve the Registrant of its full responsibility
for the adequacy and accuracy of the disclosure in the Registration Statement;  and

3.        the Registrant may not assert the
declaration of effectiveness of the Registration Statement by the Commission or
the staff as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

  Very truly yours,

  INNOVATIVE
  SOLUTIONS AND SUPPORT,

  INC.

  /s/ JAMES J. REILLY

  James J. Reilly

  Chief Financial
  Officer