Comtech Telecommunications (CMTL) CORRESPCorrespondence with SEC

Comtech Telecommunications Corp.

68 South Service Road, Suite 230

Melville, NY 11747

July 21, 2022

VIA EDGAR

Gregory Herbers

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549- 7010

Registration Statement on Form S-3 (File No. 333- 266120)

Dear Mr. Herbers:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, Comtech Telecommunications Corp. hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-3 (File No. 333-266120) so that it may become effective at 4:00 p.m. Eastern Time on July 25, 2022, or as soon thereafter as practicable.