Newton Davis
Direct Phone: (617) 951-8383
Direct Fax: (617) 951-8736
newton.davis@bingham.com
April 13, 2007
Via Edgar
Nicholas P. Panos, Special Counsel
Office of Mergers and Acquisitions
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | International Electronics, Inc. |
Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A
Filed by Rokonet Industries, U.S.A., Inc. on April 6, 2007
SEC File No. 0110-16305
Dear Mr. Panos:
On behalf of our client, Risco Ltd., a limited liability company organized under the laws of Israel (“Risco”), and its wholly-owned subsidiary, Rokonet Industries, U.S.A., Inc., a New York corporation (the “Purchaser”), submitted herewith please find Amendment No. 2 to the Preliminary Proxy Statement, File No. 0110-16305 (as amended, the “Preliminary Proxy Statement”). The Preliminary Proxy Statement has been revised to respond to the comments of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) pursuant to telephonic conversation with the Staff on April 12, 2007 (the “Comments”). In addition, the Preliminary Proxy Statement has been revised to update generally the disclosure provided therein.
For ease of reference, each comment contained in the Comments is printed below in bold and is followed by the response of the Purchaser.
Schedule 14A
General
| 1. | Revise to include disclosures required by Item 4b of Schedule 14A. |
Response: In response to the Staff’s comment, the Purchaser has revised pages 16 through 17 of the Preliminary Proxy Statement to include the information required by Item 4b of Schedule 14A.
| 2. | Revise the cover page of the Preliminary Proxy Statement to correct a typographical error. |
Response: In response to the Staff’s comments, the Purchaser has revised the cover page of the Preliminary Proxy Statement.
* * * *
Nicholas P. Panos, Special Counsel
April 13, 2007
Page 2
Should you wish to discuss the enclosed materials at any time, please do not hesitate to contact the undersigned at (617) 951-8383.
Respectfully submitted,
/s/ Newton Davis
J.Q. Newton Davis, Esq.
| cc: | Moshe Alkelai, Risco Ltd. |
John R. Utzschneider, Esq., Bingham McCutchen LLP