SecProbe.io

Mail Stop 4561
via fax (952) 974-7887

         September 14, 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 dated September 2, 2009 in connection with
the above-referenced filings and have the fo llowing comments.  If indicated, we think you
should revise your document in response to th ese comments.  If you disagree, we will
consider your explanation as to why our commen t is inapplicable or a revision is unnecessary.
Please be as detailed as nece ssary in your explanation.  In some of our comments, we may
ask you to provide us with supplemental in formation so we may better understand your
disclosure.  After reviewing this information, we may raise additional comments.  Unless otherwise noted, where prior comments are referre d to they refer to our letter dated August
24, 2009.

Forms 8-K Filed February 17, 2009, May 7, 2009 and August 6, 2009

 Use of Non-GAAP Measures

 1. We note your response to prior comment 4 and the proposed disclosures provided.
Your proposed disclosures appear overly broad and do not appear to sufficiently
reflect the guidance in Question 8 of the F AQ.  In this regard, we do not believe you
have provided substantive
 reasons why the non-GAAP me asures provide useful
information to investors.  Also, you st ate that your non-GAAP disclosures exclude
items that are “unusual, infrequent, un related to the ongoing core operations, or
involve special charges of non- cash items.”  It is not clear why you believe that items
such as depreciation and stock-based comp ensation are “unusual and infrequent.”
Further if you intend to refer to “core operati ons” in your future filings, ensure that it
is adequately defined and that you fully  explained how you determine that the

James C. Granger
Wireless Ronin, Inc. September 14, 2009 Page 2
excluded items are not representative of  your “core operations.” In addition, you do
not appear to have disclosed the material limitations associated with the use of the
non-GAAP measures or the manner in which you compensate for these limitations.  Please provide us with proposed disclosures th at fully address the concerns raised in
prior comment 4 in the event that you inte nd to present non-GAAP information in the
future.  Please note that you must meet th e burden of demonstra ting the usefulness of
any measure that excludes recurring items,  especially if the non-GAAP measure is
used to evaluate performance.
 2. Also, your proposed disclosure  indicates that you exclude  stock-based compensation
and the amortization of acquired intangibles because they are “non- cash in nature.”
Your disclosure appears to suggest that  you are using these no n-GAAP measures as
measures of both operating performance a nd liquidity.  If your non-GAAP measures
are intended to be measures of liquidity, it appears that the measures should be
reconciled to GAAP cash flow from operations .  Please clarify and explain to us why
the measure is reconciled to GAAP operating loss if your intention is to also present
this as a liquidity measure.
* * * * * * *
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