SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

Mail Stop 4561

May 14, 2010

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, 2009
Filed March 26, 2010
 File No. 001-33169

Dear Mr. Granger:
We have reviewed the above-referenced fili ng and have the following comments.  If
indicated, we think you should re vise your document in response to these comments.  If you
disagree, we will consider your explanation as to  why our comment is inapplicable 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 th is 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 requir ements 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 fr ee to call us at the
telephone numbers listed at th e end of this  letter.
 Form 10-K for the Fiscal Year Ended December 31, 2009

 Business

Select Customers, page 6

1. We note that sales to ARAMARK represente d 21.7% of total sale s in 2009, sales to
Thomson Reuters represented 15.8% of tota l sales in 2009, sales to Chrysler, through
BBDO Detroit/Windsor, represented 14.3% of total sales in 2009 and that sales to KFC
represented 10.1% in 2009.  Your relationshi ps with these customers appear to be
material and therefore you should ex pand your discussion of you contractual

James C. Granger
Wireless Ronin Technologies, Inc.  May 14, 2010 Page 2
relationships with them in your Business se ction.  Refer to Item 101(c)(1)(vii) of
Regulation S-K.  In additi on, please advise whether you ha ve agreements with these
customers upon which you are substantially dependent for purposes of Item 601 of Regulation S-K.
 Risk Factors, page 25

 2. We note your disclosure in your Form 10-K filed March 26, 2010 that pursuant to the
Loan and Security Agreement you require th e prior written consent of Silicon Valley
Bank to, among other things, dispose of a ssets, change CEO or COO, merge or
consolidate, acquire all or s ubstantially all of the capital stock or property of another
person or become liable for any indebtedness (other than permitted indebtedness).  Please tell us what consideration you gave to creati ng a risk factor in future filings discussing
the restrictions imposed by this agreement.
 Management’s Discussion and Anal ysis or Plan of Operation

 Overview, page 28

 3. Please expand this section in future filings to provide an executiv e level overview that
provides context for the remainder of the ma nagement’s discussion and analysis.  For
example, identify the factors that your ex ecutives focus on in evaluating financial
condition and operating performance and cons ider addressing the material operations,
risks and challenges facing Wireless Ronin and how manageme nt is dealing with these
issues.  Please also consider enhancing your disclosure to address any material trends.
Refer to Release No. 33-8350.
 Exhibit Index, E-1

4. In future filings, describe the exhibit refe renced in Exhibit Number 4.1.  Your current
disclosure does not respond to  the requirements of Item 601 of Regulation S-K to identify
your material exhibits.

* * * * * * *

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, you may wish to
provide us with marked copies of any amendment to expedite our review.  Please furnish a cover
letter that keys your response to  our comments and provides any re quested information.  Detailed
cover letters greatly facilitate  our review.  Please understand that we may have additional
comments after reviewing any amendment and your response to our comments.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an

James C. Granger
Wireless Ronin Technologies, Inc.  May 14, 2010 Page 3    informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.
  In connection with responding to our comment s, please provide, in writing, a statement
from the company acknowledging that:

• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in re sponse to staff comments do not foreclose the
Commission from taking any action with respect to the filing; and
• 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 sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.
 You may contact Michael F. Johnson, St aff Attorney, at (202) 551-3477, with any
questions.  If you need further assistance,  you may contact me at (202) 551-3735.
       S i n c e r e l y ,

 Barbara C. Jacobs
Assistant Director