January 5, 2009
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, June 27, 2008, and September 30, 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 December 16, 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 my telephone conversation with Ms. Levy on Friday, January 2, 2009, the Company currently anticipates submitting a response to the Comment Letter on or before January 9, 2009.
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, |
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| AVOCENT CORPORATION |
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| /s/ Samuel F. Saracino |
| Samuel F. Saracino |
| Executive Vice President of Legal and Corporate Affairs, |
cc: | Edward H. Blankenship |
| Avocent Corporation |
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| Patrick J. Schultheis, Esq. |
| Drew G. Markham, Esq. |
| Wilson Sonsini Goodrich & Rosati, Professional Corporation |
