CUTLER LAW GROUP
M. Richard Cutler, Esq
Corporate Securities Law
M Gregory Cutler, Esq.
Admitted in California & Texas
Admitted in Florida
January 6, 2012
Stephen Krikorian, Accounting Branch Chief
Evan S. Jacobson, Staff Attorney
Mark P. Shuman, Branch Chief – Legal
Melissa Walsh, Staff Accountant
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-4561
Re:
Competitive Technologies, Inc.
Form 10-K/A for the Fiscal Year Ended July 31, 2010
Filed September 15, 2011
File No. 001-08696
Post-Effective Amendment to Form S-8 Filed December 9, 2011
File No. 333-176389
Gentlemen and Ladies:
We are in receipt of your correspondence dated December 15, 2011, and addressed to Johnnie D. Johnson, Chief Executive Officer and Chief Financial Officer of the Company. This letter includes responsive comments to your letter. As a courtesy, we have attached to this letter a PDF copy of the responsive filings marked to show changes from the original filings.
The responses contained herein correspond in Part and Number to the comments in your letter of December 15, 2011. Any page numbers reflect the page numbers in the PDF copies filed simultaneously herewith.
Post-Effective Amendment No. 3 to Form S-8 Filed December 9, 2011
Incorporation of Certain Documents by Reference, page 3
1.
We reissue prior comment 1; you did not incorporate by reference your Form 10-Q for the quarter ended October 31, 2010, filed on December 15, 2010, or your Form 10-Q for the quarter ended September 30, 2011, filed on November 14, 2011, and amended on November 17, 2011. Please file an amended Form S-8 that incorporates by reference all required filings. See Item 3 of Form S-8.
We have amended the Form S-8 to incorporate the Form 10-Q for the quarter ended October 31, 2010, filed on December 15, 2010, and the Form 10-Q for the quarter ended September 30, 2011, filed on November 14, 2011, and amended on November 17, 2011.
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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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Thank you for your time and attention to this matter. Please do not hesitate to contact us should you need anything further.
Best Regards,
/s/ M. Richard Cutler
M. Richard Cutler
Cutler Law Group
3355 W. Alabama St. Suite 1150
Tel (713) 888-0040
Houston, Texas 77098
www.cutlerlaw.com
Fax (800) 836-0714
