BY EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Ms. Mara L. Ransom |
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
October 23, 2013
| Re: | Global Defense & National Security Systems, Inc. (the “Company”) Registration Statement on Form S-1 |
Registration No. 333-191195
Ladies and Gentlemen:
In connection with the above-captioned Registration Statement, we wish to advise that between October 7, 2013 and the date hereof, the aggregate number of Preliminary Prospectuses dated October 7 and October 22, 2013, respectively, which were furnished to 3 prospective underwriters and distributed to underwriters, institutional investors, individuals, dealers, brokers and others, was approximately 498. This request supersedes the requests filed on October 18 and October 22, 2013.
We have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 9:00 A.M. Washington D.C. time on October 24, 2013 or as soon as practicable thereafter.
| Very truly yours, | |
| Cowen and Company, LLC | |
| By: /s/ Andrew Mertz | |
| Name: Andrew Mertz | |
| Title: Managing Director |
