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         August 24, 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  Filed March 13, 2009  Forms 8-K Filed February 17, 2009, May 7, 2009 and August 6, 2009  File No. 001-33169

Dear Mr. Granger:

We have reviewed your response letter da ted August 12, 2009 in connection with the
above-referenced filings and have the following comments.  If indicate d, we think you should
revise your document in response to these comme nts.  If you disagree, we will consider your
explanation as to why our comment is inapplicab le or a revision is unnecessary.  Please be as
detailed as necessary in your explanation.  In some of our comments, we may ask you to
provide us with supplemental information so  we may better understand your disclosure.
After reviewing this information, we may raise additional comments.  Unless otherwise noted, where prior comments are referred to th ey refer to our letter dated July 29, 2009.

Form 10-K for the Fiscal Year Ended December 31, 2008

 Item 7.  Management’s Discussion and Analys is of Financial Condition and Results of
Operations

Liquidity and Capital Resources
 Operating Activities, page 40

1. We note your response to prior comment 2 a nd believe that the information provided
in your response would be useful to an investors’ understanding of the makeup of
your cash flows from operati ng activities.  In this rega rd, a thorough unde rstanding of
the reason for timing differences that result from receipt of paym ents from customers

James C. Granger
Wireless Ronin, Inc. August 24, 2009 Page 2
or payments to vendors would provide i nvestors more insight to the Company’s
operations as seen through the eyes of ma nagement.  Please revise your disclosures
accordingly.  Also, we note from your re sponse to prior comments 1 and 2 that you
intend to revise your disclosures in future  filings.  Please ensure that you will make
these revisions in your next Form 10-Q as  the Staff notes these issues were not
addressed in your most recent interim period filing.
 Notes to Consolidated Financial Statements

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

 Revenue Recognition, page F-7

 2. We note from your response to prior co mment 3 that the Company’s SOP 81-1
contracts are all classified within “services  and other” on the cons olidated statements
of operations as the “only deliverable is pr ofessional services.”  Please note that
footnote 1 of SOP 81-1 does not permit the use of contract a ccounting for service
contracts.  In this regard , please tell us how you determ ined that the percentage-of
completion method of accounting is app licable to your technology integration
consulting services contracts.

3. We note your response to our prior comment  4 where you provide the range of hourly
rates charged for your various service o fferings (i.e. content creation, software
development). We also note from your res ponse that the billable rates are adjusted
based on the size and scope of the project . Please describe further your methodology
for establishing VSOE of fair value for such  services.  In this regard, tell us the
criteria considered in analyzing VSOE for su ch services (i.e. type of service, duration
of contract, scope of contract, customer size, etc.).  Additionally, if you assessed
VSOE based on a bell-shaped-curve approach, please tell us the percentage of stand
alone sales that fall within a narrow range of  the median price for each  criteria used
in your analysis.
 Forms 8-K Filed February 17, 2009, May 7, 2009 and August 6, 2009

 Use of Non-GAAP Measures

 4. Please clarify your response to prior comme nt 7 where you indicate that “the items
excluded for non-GAAP purposes ar e non-recurring in nature.”  In this regard, we
note you exclude stock based compensation as  well as depreciation and amortization,
which would appear to be recurring e xpenses as a result of ongoing business
operations.  Further, provide in your respons e the proposed disclosures that you intend
to include in future earnings releases.  In this regard, please ensure such disclosures
include the following items as the inform ation provided in your response did not
adequately address the disclo sures required by FAQ 8:

James C. Granger
Wireless Ronin, Inc. August 24, 2009 Page 3
• 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 manageme nt believes the non-GAAP financial
measure provides useful in formation to investors.
* * * * * * *
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 marked copies of a ny amendment to expedite our review.  Please
furnish a cover letter that keys your response to our comments and provides any requested
information.  Detailed cover lette rs greatly facilitate our revi ew.  Please understand that we
may have additional comments after reviewi ng any amendment and your response to our
comments.

 You may contact Jason Nietha mer, Senior Staff Accountan t, at (202) 551-3855 or me
at (202) 551-3499 if you have any ques tions regarding the above comments.

      S i n c e r e l y ,
/s/ Kathleen Collins
       Kathleen Collins
Accounting Branch Chief