March 15, 2010



      VIA EDGAR
      Ms. Lyn Shenk
      Branch Chief
      Division of Corporate Finance
      100 F Street, N.E.
      Washington, D.C. 20549-7010

      RE:  VALCOM, INC.
           FILE NUMBER 000-28416
           FORM 10-K: FOR THE FISCAL YEAR ENDED SEPTEMBER 30, 2009
           FORM 8-K FILED FEBRUARY 4, 2010

      Dear Ms. Shenk:

      We  have  reviewed  the  comments contained in your letter dated March 5,
      2010 and submit the following responses.


      Form 10-K: For the Fiscal Year Ended September 30, 2009
      Notes to the Consolidated Financial Statements, page F-7
      Note 4: Restatement, page F-10

      1.We note that you restated your financial statements for the fiscal year
        ended September 30, 2009  and  September 30, 2008.  Please file an Item
        4.02 Form 8-K immediately.  The  filing was due on the fourth day after
        the  date  that  you  concluded that the  previously  issued  financial
        statements should not be  relied  upon.   The Item 4.02 Form 8-K should
        disclose  when  you  concluded  that your previously  issued  financial
        statements should be restated, identify  the  financial statements that
        should no longer be relied upon, and state whether the audit committee,
        or  board  of  directors  in  the  absence  of an audit  committee,  or
        authorized  officer  or  officers,  discussed  with   the   independent
        accountant the matters disclosed in the Item 4.02 Form 8-K.   Section 4
        of Form 8-K describes all of the disclosures required by the Item  4.02
        Form  8-K.   In  addition,  please tell us why you did not file an Item
        4.02 Form 8-K.

        Response:
        In connection with the Commission's  Comment  #1, the Company has filed
        an Item 4.02 Form 8-K.


      Item 4.01 Form 8-K: filed February 4, 2010

      2.Please  amend  your  Form 8-K to state whether, during  your  two  most
        recent fiscal years and  any  subsequent  interim  period,  the Company
        consulted  with  M&B regarding either (i) the application of accounting
        principles to a specific  completed or contemplated transaction, of the
        type of audit opinion that might be rendered on the Company's financial
        statements  or  (ii) any matter  that  was  either  the  subject  of  a
        disagreement or event  identified in response to (a)(1)(iv) of Item 304
        of Regulation S-K.  The  disclosure that was made in the Item 4.01 Form
        8-K  filed  on February 4, 2010  states  only  during  the  year  ended
        September 30,  2009  and  not  the required disclosure of your two most
        recent fiscal years and any subsequent interim period.

        Response:
           In connection with the Commission's  Comment  #2,  the Company
           has  amended its Item 4.01 Form 8-K to accurately reflect  the
           time period referenced.


      The Company acknowledges the following:


      *   The Company  is  responsible  for  the  adequacy  and accuracy of the
      	  disclosure in all of its filings;
      *   Any changes to disclosure in response to the Commission's 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.

                                     *****

      We appreciate your timely consideration of these  matters  in your review
      of  the  filing referenced above. If you or others have any questions  or
      would like additional information, please contact me directly.


				Very truly yours,


				/s/ Vince Vellardita
				Vince Vellardita