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SEC Company Response from INNOVATIVE SOLUTIONS & SUPPORT INC (ISSC) (CIK 0000836690) (IA) — Mar 16, 2011

INNOVATIVE SOLUTIONS & SUPPORT INC (ISSC) (CIK 0000836690)
Date: March 16, 2011 · CIK: 0000836690 · Accession: 0001104659-11-014914

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File numbers found in text: 001-31157

Referenced dates: March 2, 2011

Date
March 16, 2011
Author
Ronald C. Albrecht
Form
CORRESP
Company
INNOVATIVE SOLUTIONS & SUPPORT INC (ISSC) (CIK 0000836690)

Letter

VIA EDGAR Division of Corporate Finance Washington, D.C. 20549 Re: Innovative Solutions & Support, Inc. Form 10-K for the Fiscal Year Ended September 30, 2010 Filed December 14, 2010 Form 10-Q for the Quarter ended December 31, 2010 Filed February 8, 2011 File No. 001-31157

Dear Ms. Collins:

Innovative Solutions and Support, Inc. (the “Company”) confirms receipt of the letter dated March 2, 2011 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) with respect to the above-referenced Form 10-K and Form 10-Q. In response to the Staff’s comments, the Company acknowledges that:

(1) The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

(2) 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

(3) 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.

Very truly yours,
INNOVATIVE SOLUTIONS AND SUPPORT, INC.

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CORRESP
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March 16, 2011

VIA EDGAR

Kathleen Collins

Accounting Branch Chief

Division of Corporate Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Re:                                                 Innovative Solutions & Support, Inc.
 Form 10-K for the Fiscal Year Ended September 30, 2010
 Filed December 14, 2010

Form 10-Q for the Quarter ended December 31, 2010

Filed February 8, 2011
 File No. 001-31157

Dear Ms. Collins:

Innovative Solutions and Support, Inc. (the “Company”) confirms receipt of the letter dated March 2, 2011 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) with respect to the above-referenced Form 10-K and Form 10-Q. In response to the Staff’s comments, the Company acknowledges that:

(1)                                 The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

(2)                                 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

(3)                                 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.

Very   truly yours,

INNOVATIVE   SOLUTIONS AND SUPPORT, INC.

/s/   Ronald C. Albrecht

Ronald   C. Albrecht

Chief   Financial Officer