Viisage Technology, Inc.
296 Concord Road
Third Floor
Billerica, MA 01821
July 27, 2006
Via EDGAR and Facsimile
Rebekah Toton, Esq.
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Mail Stop 4561
| Re: | Viisage Technology, Inc. – Request for Acceleration of Effectiveness of |
| | Registration Statement on Form S-4 (File No. 333-131843) |
Dear Ms. Toton:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Viisage Technology, Inc. (the “Company”), hereby requests that the Company’s Registration Statement on Form S-4 (File No. 333-131843) be declared effective on July 27, 2006 at 2:00 PM Eastern Standard Time, or as soon as possible thereafter.
The Company acknowledges that:
| • | | should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the above registration statement effective, it does not foreclose the Commission from taking any action with respect to such registration statement; |
| • | | the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the above registration statement effective, does not relieve the Company of its full responsibility for the adequacy and accuracy of the disclosure in such registration statement; and |
| • | | the Company may not assert Staff comments or the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please contact the undersigned at (978) 932-2466 if you have any questions. Thank you for your assistance.
Very truly yours,
/s/ Elliot J. Mark
Elliot J. Mark
Senior Vice President and General Counsel