SecProbe.io

CORRESP
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        Jeffrey P. Schultz | 212
        692 6732 | jpschultz@mintz.com

        Chrysler Center

        666 Third Avenue

        New York, NY 10017

        212-935-3000

        212-983-3115 fax

        www.mintz.com

June 19, 2012

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 3561

Washington, D.C. 20549

Attention: Larry Spirgel, Assistant Director

 Re: Vringo, Inc.

Amendment No. 3 to Registration Statement
on Form S-4

Filed June 12, 2012

File No. 333-180609

Ladies and Gentleman:

On behalf of Vringo, Inc. (the “Company”
or “Vringo”), we hereby file with the Securities and Exchange Commission (the “Commission”)
responses to the oral comments of the staff of the Commission’s Division of Corporation Finance (the “Staff”)
received on June 19, 2012 and as set forth below, with regard to the Company’s Registration Statement on Form S-4 (File No.
333-180609), initially filed with the Commission on April 6, 2012 and as previously amended on May 17, 2012, June 1, 2012 and June
12, 2012 (the “Registration Statement”).

 1. Please specify and discuss in more detail the disclosure in the fourth paragraph on page 78 regarding Vringo’s stockholders’
percentage ownership in the combined entity and the implied valuation of Innovate/Protect.

Response: In response
to the Staff’s comment, the Company will add the following disclosure to page 78 of the definitive proxy statement/424b prospectus
with respect to the Registration Statement:

“Based upon
the percentage ownership of the Vringo stockholders in the combined entity (32.45% on a fully diluted basis) even the high end
range of the implied Vringo Comparable Company Analysis ($20.7 million) supported the fairness of the Merger consideration, from
a financial point of view, to the holders of the Vringo common stock in comparison to the implied valuation of Innovate/Protect
($55.5 million) as described under the caption “Innovate/Protect Comparable Companies analysis”. This analysis resulted
in the high end implied valuation of Vringo being 27.3% of the combined implied comparable company valuations of Vringo and Innovate/Protect.
As a result of the Merger, Vringo stockholders will receive a percentage (32.45%) of the outstanding common stock of the combined
company calculated on a fully diluted basis that is higher than 27.3%.”

Mintz, Levin, Cohn, Ferris, Glovsky and
Popeo, P.C.

Boston
| Washington | New York | Stamford | Los Angeles | San Diego | London | San Francisco

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo,
P.C.

Securities and Exchange Commission

June 19, 2012

Page 2

 2. Please update your proxy statement/prospectus for recent developments in the Innovate/Protect’s litigation.

Response:
In response to the Staff’s comment, the Company will add the following paragraph (and replace the second and third full paragraphs)
which updates the information relating to the Innovate/Protect’s litigation to page 152 of the definitive proxy statement/424b prospectus
with respect to the Registration Statement:

	“Within
the Markman, or claim construction process, the court reviewed the parties competing definitions for specific terms within
the asserted claims. Both parties submitted two rounds of briefing to the court that provided arguments for their proposed definitions.
The opening claim construction briefs were filed on April 12, 2012, and the responsive claim construction briefs were filed on
May 3, 2012. At the Markman hearing on June 4, 2012, the court heard arguments from both sides in support of their positions.
On June 15, 2012, the court issued a Memorandum Opinion & Order providing binding definitions for the contested terms. The
court’s definitions to the patent claims established the boundary markings of the claimed technology and inform both parties’
expert reports and testimony as well as the parties’ arguments to the jury. The court’s Memorandum Opinion & Order
construing the contested terms is publicly available on the Public Access to Court Electronic Records (PACER) electronic public
access service at http://www.pacer.uscourts.gov/, and was also filed by Vringo with the Securities
and Exchange Commission.”

*	*	*	*	*

When appropriate, the
Company will provide a written request for acceleration of the effective date of the Registration Statement and will include the
requested “Tandy” language therein. The Company is aware of its obligations under Rules 460 and 461 regarding requesting
acceleration of the effectiveness of the Registration Statement.

We hope that the above
responses and the related revisions to the Registration Statement will be acceptable to the Staff. Please do not hesitate to call
me at (212) 692-6732 with any comments or questions regarding the Registration Statement and this letter. We thank you for your
time and attention.

    Sincerely,

    /s/ Jeffrey P. Schultz

    Jeffery P. Schultz

 cc: Securities and Exchange Commission

Ajay Koduri, Staff
Attorney

Vringo, Inc.

Andrew
D, Perlman, Chief Executive Officer and President

Ellen
Cohl, Chief Financial Officer