TEXT-EXTRACT 2 filename2.txt March 6, 2020 Michael D. Porcelain Senior Vice President and Chief Operating Officer Comtech Telecommunications Corp./DE/ 68 South Service Road, Suite 230 Melville, NY 11747 Re: Comtech Telecommunications Corp./DE Registration Statement on Form S-4 Filed March 2, 2020 File No. 333-236840 Dear Mr. Porcelain: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Asia Timmons-Pierce at 202-551-3754 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing