SecProbe.io

Mail Stop 4561         July 29, 2009  James C. Granger Chief Executive Officer Wireless Ronin Technologies, Inc. 5929 Baker Road, Suite 475 Minnetonka, MN 55345
Re: Wireless Ronin Technologies, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2008
Forms 8-K Filed February 17, 2009 and May 7, 2009
 File No. 001-33169

Dear Mr. Granger:
We have reviewed the above-referenced f ilings and have the following comments.
Please note that we have limited our review to only your financial statements and related
disclosures and do not intend to expand our revi ew to other portions of your document.
If indicated, we think you should revise your  document in response to these comments.
If you disagree, we will consider your explana tion as to why our comment is inapplicable
or a revision is unnecessary.  Please be as de tailed as necessary in your explanation.  In
some of our comments, we may ask you to pr ovide us with supplemental information so
we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.
 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comments or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Form 10-K for the Fiscal Year Ended December 31, 2008

 Item 7.  Management’s Discussion a nd Analysis or Plan of Operations

 Results of Operations, page 36

 1. In the discussion of your results of opera tions, you refer to various factors that
have impacted revenue without quantif ying the impact of each factor.  For

James C. Granger
Wireless Ronin Technologies, Inc. July 29, 2009 Page 2
example, you disclose that the increase in  sales was the result of new customer
relationships, the expansion of existing customer relati onships and a full year of
sales from your Canadian operations, offs et by the loss of a large customer in
2007 but you give no indication as to the re lative impact of each factor.  Please
explain to us how you considered Sec tion III.D of SEC Release No. 33-6835 and
Section III.B of SEC Release No. 33-8350.  No te that this comment also applies
to your discussion on changes to cost of sales and various operating expenses.
 Liquidity and Capital Resources

 Operating Activities, page 40

 2. We note that your discussion of cash flows from operating activi ties is essentially
a recitation of the r econciling items identified on th e face of the statement of cash
flows.  This does not appear to contri bute substantively to an understanding of
your cash flows. Rather, it repeats items th at are readily determinable from the
financial statements.  When preparing the discussion and analysis of operating
cash flows, you should address material changes in the underlying drivers that
affect these cash flows. These disclosures should also include a discussion of the
underlying reasons for changes in working cap ital items that affect operating cash
flows.  Please tell us how you considered  the guidance in Section IV.B.1 of SEC
Release 33-8350.
 Consolidated Statements of Operations, page F-4

 3. Your disclosures indicate that for ce rtain arrangements, the Company recognize
revenue pursuant to SOP 81-1. Tell us th e amount of revenues recognized using
contract accounting for each period presen ted.  Also, tell us  where you classify
these revenues and related costs in your Consolidated Statements of Operations.
If you classify these revenues and related costs as a single line item (i.e. within
“Services and other”) or a llocate between products and services, please explain
your basis of presentation or allo cation methodology, why you believe such
presentation is reasonable and confirm to  us that this presentation has been
consistently applied.  Assuming that your  presentation of revenues and cost of
revenues is considered reasonable for purpos es of complying with Rule 5-03(b)(1)
and (2) of Regulation S-X, please ensure  that your MD&A, Critical Accounting
Policies and Estimates and footnote disclo sures include a discussion of your basis
of presentation or allocation methodol ogy and discuss the reasons for such
presentation or allocation.

James C. Granger
Wireless Ronin Technologies, Inc. July 29, 2009 Page 3  Notes to Consolidated Financial Statements

 Note 1. Nature of Operations and Su mmary of Significant Accounting Policies

 Revenue Recognition, page F-7

 4. We note that you derive revenue from mu ltiple element arrangements that include
a combination of software products, system hardware, maintenance and support, or installation and training services in  accordance with SOP 97-2.  Please describe
your methodology for establishing vendor-s pecific objective evidence (“VSOE”)
of fair value for each of your elements , the accounting literature you considered,
and how you considered disclosing your policy in your revenue recognition footnote.  If VSOE is based on stated renewal rates then please tell us how you
determined the renewal rates are substantiv e.  In this regard, please provide the
range of renewal rates and tell us what  percentage of your customers actually
renew at such rates.  Alte rnatively, if VSOE is based on stand-alone sales, then
provide the volume and range of stand alone sales used to establish VSOE.  Also,
please describe the various factors that affect your VSOE analysis including customer type and other pricing f actors (e.g., geographic region, purchase
volume, competitive pricing, perpetua l versus term license, etc.).

5. We note your disclosure that you defer revenue under the residual method for
undelivered maintenance and support fees included in the price of software.
Reconcile this statement with your di sclosure that “each element of [your]
multiple element arrangements qualifies  for separate accounting with the
exception of undelivered maintenance and serv ice fees.”  In this regard, explain
how you utilize the residual method for elem ents that do not qualify for separate
accounting.
 6. We note that the Company records reve nue from your SOP 81-1 contracts based
on the percentage of services provid ed during the reporting period to total
estimated services to be provided over the duration of the contract.  Please explain
further what you mean by “services provided.”   In this regard, clarify whether you
recognize revenue using input measures or  output measures and tell us what
specific measures are used to determin e “services provided”  (i.e. labor hours,
service milestones, etc.).  Also, please c onsider revising your disclosures to more
clearly describe how you measure progre ss to completion for the Company’s SOP
81-1 contracts.
 Use of Non-GAAP Measures

 7. We note your use of non-GAAP measures in  the Form 8-Ks filed February 17,
2009 and May 7, 2009 that exclude a number of items that appear to be recurring in nature.  Please revise to include th e following disclosures pursuant to Question

James C. Granger
Wireless Ronin Technologies, Inc. July 29, 2009 Page 4
8 of Frequently Asked Questions Rega rding the Use of Non-GAAP Financial
Measures:

• the economic substance behind management 's decision to use such a measure;
• the material limitations associated with use of the non-GAAP financial
measure as compared to the use of the most directly comparable GAAP
financial measure;
• the manner in which management compensates for these limitations when
using the non-GAAP financial measure; and
• the substantive
 reasons why management be lieves the non-GAAP financial
measure provides useful in formation to investors.
 In this regard, we believe you should furt her enhance your disclosures to comply
with Item 10(e)(1)(i)(C) a nd (D) of Regulation S-K and Question 8 of the related
FAQ to demonstrate the usefulness of your non-GAAP financial measures, which
appear to exclude certain items that coul d be considered non-recurring in nature,
especially since these measur es appear to be used to evaluate performance.

* * * * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your
filing(s), you may wish to provide us with ma rked copies of any amendment to expedite
our review.  Please furnish a cover letter that  keys your response to our comments and
provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.
 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 all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a
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

James C. Granger
Wireless Ronin Technologies, Inc. July 29, 2009 Page 5

• 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.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact Jason Nietha mer, Senior Staff Account ant, at (202) 551-3855 or
me at (202) 551-3499 if you have any questi ons regarding the above comments.
        S i n c e r e l y ,         /s/ Kathleen Collins        Kathleen Collins
Accounting Branch Chief