Mail Stop 4-7

April 26, 2005

Malcolm C. Persen
Chief Financial Officer
Radyne ComStream Inc.
3138 East Elwood Street
Phoenix, AZ 85034

Re: 	Radyne ComStream Inc.
Form 10-K for the fiscal year ended Dec. 31, 2004, filed March 16,
2005
File No. 0-11685

Dear Mr. Persen:

      We have reviewed the referenced filing and your response
letter
dated April 11, 2005, and have the following comments.  We have
limited our review to only your financial statements and related
disclosures and will make no further review of your documents.  As
such, all persons who are responsible for the adequacy and
accuracy
of the disclosure are urged to be certain that they have included
all
information required pursuant to the Securities Exchange Act of
1934.
Please amend your filing in response to these comments.  If you
disagree with any of these comments, 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 this information, we may or may not raise
additional
comments.


Form 10-K for the fiscal year ended December 31, 2004, filed March
16, 2005

Item 9A - Controls and Procedures, page 43

1. We note your draft revisions in response to prior comment 4.
Your
draft revisions state that there were no changes in "other factors
that have materially affected, or are reasonably likely to
materially
affect these controls subsequent to the date of their evaluation."
Please note that Item 308(c) of Regulation S-K no longer refers to
"other factors," and Item 308(c) now requires evaluation of
changes
"during the registrant`s last fiscal quarter."  Please further
revise
accordingly.  See Item 308(c) of Regulation S-K, which became
effective on August 14, 2003.  Further, in future filings, please
comply with Item 308(c) of Regulation S-K.  See also Section II.J.
of
Securities Act Release No. 33-8238 (June 5, 2003), which is
available
on our web site at http://www.sec.gov/rules/final/33-8238.htm#iij.


*   *   *   *   *


      As appropriate, please amend your periodic report and
respond
to these comments within 10 business days or tell us when you will
provide us with a response.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
submit
your cover letter as correspondence on EDGAR.  Please understand
that
we may have additional comments after reviewing your amendment and
responses to our comments.

      You may contact Christine Bashaw, Staff Accountant, at (202)
551-3363 if you have questions regarding comments on the financial
statements and related matters.  Please contact Daniel Zimmerman,
Staff Attorney, at (202) 551-3367 or me at (202) 551-3810 with any
other questions.


Sincerely,



Larry Spirgel
Assistant Director