CUTLER LAW GROUP
M. Richard Cutler, Esq
Corporate Securities Law
M Gregory Cutler, Esq.
Admitted in California & Texas
Admitted in Florida
July 12, 2011
Stephen Krikorian, Accounting Branch Chief
Evan S. Jacobson, Staff Attorney
Mark P. Shuman, Branch Chief - Legal
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-4561
Re:
Competitive Technologies, Inc.
Form 10-K for the Fiscal Year Ended July 31, 2010 Filed October 27, 2010
Form 10-K/A for the Fiscal Year Ended July 31, 2010 Filed March 4, 2011
Form 10-Q for the Quarterly Period Ended October 31, 2010 Filed December 15, 2010
Form 10-Q/A for the Quarterly Period Ended October 31, 2010 Filed March 4, 2011
Transition Report on Form 10-Q for the Transition Period from November 1, 2010 to December 31, 2010 Filed February 22, 2011
Form 10-Q for the Quarterly Period Ended March 31, 2011 Filed May 20, 2011
Form 8-Ks Filed on September 13, 2010, December 15, 2010,
February 11, 2011, March 1, 2011, April 19, 2011, and May 4, 2011
File No. 001-08696
Gentlemen and Ladies:
We are in receipt of your correspondence dated May 25, 2011, and addressed to Johnnie D. Johnson, Chief Executive Officer and Chief Financial Officer of the Company. We acknowledge and recognize that the Commission has requested our response within ten businesses days, and that our letter of June 28 had stated that we expected to have our response on or before July 6, 2011. This letter is to request an additional extension of time in order to submit our response to comments contained in your letter of May 25.
As stated in our letter of June 28, the substantive changes to our 10-K have necessitated full review by our management, and by our auditor at both the account manager and peer review level. Although we had anticipated completing our response by July 1, we have experienced additional delays in the review process by our auditor and in responding to our auditor’s comments.
We are currently in the final auditor review phase and anticipate filing on Thursday, July 14, 2011. We will file a Correspondence filing on that date should we be unable to file our response and amended 10-K
Please note that although we have substantive changes to our 10-K, none of the changes involve a restatement of any part of our financial statements, or any financial information contained in the other parts of the 10-K.
3355 W. Alabama St. Suite 1150
Tel (713) 888-0040
Houston, Texas 77098
www.cutlerlaw.com
Fax (800) 836-0714
CUTLER LAW GROUP
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Please feel free to call me at any of the numbers listed on this letter if you have further questions or comments.
Best Regards,
\s\ M Gregory Cutler
M Gregory Cutler
3355 W. Alabama St. Suite 1150
Tel (713) 888-0040
Houston, Texas 77098
www.cutlerlaw.com
Fax (800) 836-0714
