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SEC Company Response from AVIAT NETWORKS, INC. (AVNW) (CIK 0001377789) (AVNW) — Jan 22, 2009

AVIAT NETWORKS, INC. (AVNW) (CIK 0001377789)
Date: Jan. 22, 2009 · CIK: 0001377789 · Accession: 0000950134-09-000857

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File numbers found in text: 001-33278

Referenced dates: January 15, 2009

Date
January 22, 2009
Author
President and
Form
CORRESP
Company
AVIAT NETWORKS, INC. (AVNW) (CIK 0001377789)

Letter

Division of Corporation Finance Securities and Exchange Commission Harris Stratex Networks, Inc. Form 10-K for year ended June 27, 2008 Filed September 25, 2008 File No. 001-33278

Dear Mr. Bartelmes:

On behalf of Harris Stratex Networks, Inc. (“Harris Stratex”), I hereby submit our response to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on Harris Stratex’ Annual Report on Form 10-K for the fiscal year ended June 27, 2008 (the “Form 10-K”), as set forth in your letter dated January 15, 2009 (the “Comment Letter”).

We have duly noted comment nos. 1. - 5. in the Comment Letter. In consideration of these comments, in future filings we will address the matters raised by each of the comments to the extent then applicable.

Harris Stratex Acknowledgement:

Harris Stratex acknowledges the following:

•

Harris Stratex 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

•

Harris Stratex 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.

If you have any questions or comments in connection with the foregoing please call me at (919) 767-3250 or Sarah A. Dudash, Senior Vice President and Chief Financial Officer, at (919) 767- 3352. Facsimile transmissions may be sent to either of us at (919) 767-3230.

Very truly yours,
/s/ Harald J. Braun

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CORRESP
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corresp

    637 Davis Drive

Morrisville, NC 27560 USA

phone 1-919-767-3230

fax 1-919-767-3233

    www.harrisstratex.com

Harald Braun

President and

Chief Executive Officer

Via Electronic Submission (Correspondence)

January 22, 2009

Mr. Robert Bartelmes

Senior Financial Analyst

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    RE:

    Harris Stratex Networks, Inc.

Form 10-K for year ended June 27, 2008

Filed September 25, 2008

File No. 001-33278

Dear Mr. Bartelmes:

On behalf of Harris Stratex Networks, Inc. (“Harris Stratex”), I hereby submit our response
to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the
Securities and Exchange Commission (the “Commission”) on Harris Stratex’ Annual Report on
Form 10-K for the fiscal year ended June 27, 2008 (the “Form 10-K”), as set forth in your
letter dated January 15, 2009 (the “Comment Letter”).

We have duly noted comment nos. 1. - 5. in the Comment Letter. In consideration of these comments,
in future filings we will address the matters raised by each of the comments to the extent then
applicable.

Harris Stratex Acknowledgement:

Harris Stratex acknowledges the following:

    •

    Harris Stratex 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

    •

    Harris Stratex 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.

If you have any questions or comments in connection with the foregoing please call me at (919)
767-3250 or Sarah A. Dudash, Senior Vice President and Chief Financial Officer, at (919) 767- 3352.
Facsimile transmissions may be sent to either of us at (919) 767-3230.

Very truly yours,

/s/ Harald J. Braun

Harald J. Braun

President and Chief Executive Officer

    cc:

    Jessica Plowgian, Attorney-Adviser Securities and Exchange Commission
Sarah A. Dudash, Senior Vice President and Chief Financial Officer, Harris Stratex
Networks, Inc.

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