-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, V+NUfPiLPQuiAVOk7+FpZ1jif8voq76+HKm4GcbsRU1ba0zau1qcV9PCfli51yFo +k6YjF3cCmzi9Og2tbYrHw== 0000092769-09-000009.txt : 20090928 0000092769-09-000009.hdr.sgml : 20090928 20090804154305 ACCESSION NUMBER: 0000092769-09-000009 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20090804 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SPECTRUM CONTROL INC CENTRAL INDEX KEY: 0000092769 STANDARD INDUSTRIAL CLASSIFICATION: ELECTRONIC COMPONENTS, NEC [3679] IRS NUMBER: 251196447 STATE OF INCORPORATION: PA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 8031 AVONIA ROAD CITY: FAIRVIEW STATE: PA ZIP: 16415 BUSINESS PHONE: 8144744310 MAIL ADDRESS: STREET 1: 8031 AVONIA ROAD CITY: FAIRVIEW STATE: PA ZIP: 16415 CORRESP 1 filename1.htm

Spectrum Control, Inc.
8031 Avonia Rd.
Fairview, PA 16415

August 4, 2009

Celia A. Soehner, Attorney
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E
Washington, DC 20549-6010
Mail Stop 3030

Re:		Spectrum Control, Inc. Form 10-K for the fiscal year ended November 30, 2008 Filed February 12, 2009 File No. 000-08796
Dear Attorney Soehner:
In connection with the above referenced matter, we have received your comment as set forth in your letter dated July 28, 2009 (a copy of which is attached hereto). Our response to your comment is set forth below.
1.	Comment regarding "Base Salary", page 11
		Regarding the first paragraph of your response to prior comment 3, please confirm that in future filings you will clarify the extent to which the Compensation Committee relies upon peer group and survey data when determining the base salaries of named executives and explain how the Committee evaluates and considers the other elements that you list on page 11, such as individual performance. From your current disclosure in this section, it is unclear that "applicable peer group and survey data are the most significant factors in determining the base salaries of the named executives."
	Response
		We hereby confirm that, in future filings, we will clarify the extent to which the Compensation Committee relies upon peer group and survey data when determining the base salaries of named executives, and explain how the Committee evaluates and considers other elements such as individual performance.
If you have any further questions or comments, please contact the undersigned at (814) 474-4312.

Sincerely,

/s/ John P. Freeman

John P. Freeman CPA, CMA
Senior Vice President
and Chief Financial Officer

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