UNITED STATES
                                 SECURITIES AND EXCHANGE COMMISSION
                                             WASHINGTON, D.C. 20549


      DIVISION OF
CORPORATION FINANCE
                                                              August 20, 2019



 H. Timothy Eriksen
 CEO and Interim CFO
 Solitron Devices, Inc.
 3301 Electronics Way
 West Palm Beach, FL 33407

         Re:     TSR, Inc.
                 PRRN4A filed by H. Timothy Eriksen, et al.
                 Filed August 15, 2019
                 File No. 001-38838

 Dear Mr. Eriksen:

         We have reviewed the above-captioned filing, and have the following
comments. Some
 of our comments may ask for additional information so we may better understand
the disclosure.

        Please respond to this letter by amending the filing and/or by
providing the requested
 information. If you do not believe our comments apply to your facts and
circumstances and/or
 do not believe an amendment is appropriate, please tell us why in a written
response.

         After reviewing any amendment to the filing and/or any information
provided in response
 to these comments, we may have additional comments.

 Schedule 14A

 1. We have reviewed the response submitted in reply to prior comment number
two in our letter
    dated August 13, 2019, and concluded that the information provided
regarding the "corporate
    family," as described in the participants' correspondence dated August 15,
2019, is
    insufficient for us to make a final determination as to whether Zeff
Capital, L.P., Zeff
    Holding Company, LLC, and Daniel Zeff should be reporting beneficial
ownership as a
    group. Section 13(d)(1), by its terms, applies to a "person" and is
indifferent to the purported
    or actual existence of a "corporate family." Notwithstanding the definition
of "person" in
    Section 3(a)(9) of the Securities Exchange Act of 1934, application of
Section 13(d)(3)
    results in two or more persons being regulated as a single person under
Section 13(d)(1) if
    they "act as" a group for the purpose of acquiring, holding or disposing of
a voting class of
    Section 12-registered equity securities. Each member of the group bears an
obligation to
    report beneficial ownership on behalf of the group under Rule 13d-1(k).
Please advise us
    whether the "Zeff Group" acts as a group within the meaning of Section
13(d)(3).
 H. Timothy Eriksen
August 20, 2019
Page 2

2. Please advise us, with a view toward revised disclosure, whether or not the
"Zeff Group",
   Fintech Consulting LLC and QAR Industries, Inc. are acting as a group within
the meaning
   of Section 13(d)(3). Please specifically address whether or not these
parties have acted in
   concert to nominate directors at TSR and, if so, whether such action
constituted a joint effort
   to "hold" the equity securities of TSR within the meaning of Section
13(d)(3). Please also
   specifically address whether a group existed as early as 2018 for the
purpose of acquiring
   TSR equity securities within the meaning of Section 13(d)(3) Refer to
exhibit 99.1 to the
   Schedule 13D filed by Joseph Hughes on July 17, 2018 in which Zeff Capital,
LP, QAR
   Industries, Inc. and Fintech Consulting LLC were characterized as a "group"
that sought to
   acquire approximately 819,000 shares. To the extent a group existed, Rule
13d-5, titled
   "Acquisition of securities," could apply (if its conditions were met) and
would require a
   Schedule 13D to be filed within 10 days of the acquisition that would have
been deemed to
   occur. Given that no Schedule 13D (or Schedule 13G) has been filed, please
advise us
   whether or not a legal conclusion was reached that no such filing was or is
currently required.

                                        *       *       *

        We remind you that the participants are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

        You may contact me at (202) 551-3266 with any questions.


                                                            Sincerely,

                                                            /s/ Nicholas P.
Panos

                                                            Nicholas P. Panos
                                                            Senior Special
Counsel
                                                            Office of Mergers
and Acquisitions


cc: Douglas K. Schnell, Esq.