November 13, 2008
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Mail Stop 4-6
Washington, D.C. 20549-0406
Attn: | | Stephen G. Krikorian |
| | Accounting Branch Chief |
| | Tamara Tangen |
| | Staff Accountant |
| | Donna Levy |
| | Staff Attorney |
| | Barbara C. Jacobs |
| | Assistant Director |
Re: Avocent Corporation
Form 10-K for the Fiscal Year Ended December 31, 2007 filed February 21, 2008
Forms 10-Q for the Fiscal Quarters Ended March 28, 2008 and June 27, 2008
Definitive Proxy Statement on Schedule 14A filed April 25, 2008
File No. 000-30575
Ladies and Gentlemen:
On behalf of Avocent Corporation (the “Company”), this letter is being submitted in reference to the Securities and Exchange Commission’s letter to Edward H. Blankenship, Senior Vice President of Finance and Chief Financial Officer of the Company, dated October 29, 2008 (the “Comment Letter”).
The Company is working expeditiously to respond to the Comment Letter. The Company respectfully requests an extension of time to respond to the inquiries contained in the Comment Letter. Per the telephone message I left for Ms. Levy on Wednesday, November 12, 2008, and her voice mail response to me this morning, the Company currently anticipates submitting a response to the Comment Letter on or before November 21, 2008.
Please do not hesitate to contact me (425-497-5596) or Mr. Blankenship (256-217-1301), with any concerns you may have regarding the timetable described above.
Thank you for your consideration.
| Sincerely, |
| |
| AVOCENT CORPORATION |
| |
| /s/ Samuel F. Saracino |
| |
| Samuel F. Saracino |
| Executive Vice President of Legal and Corporate Affairs, General Counsel and Secretary |
cc: Edward H. Blankenship
Avocent Corporation
Patrick J. Schultheis, Esq.
Drew G. Markham, Esq.
Wilson Sonsini Goodrich & Rosati, Professional Corporation