NEW YORK 212-530-5000 FAX: 212-530-5219
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______________
DAVID E. ZELTNER PARTNER DIRECT DIAL NUMBER 212-530-5003 Fax: 212-822-5003 E-MAIL: dzeltner@milbank.com
October 25, 2011 |
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Via EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-3628
Attention: Larry Spirgel,
Assistant Director
| Re: | Comverse Technology, Inc. |
| Form 10-K for the Fiscal Year Ended January 31, 2011 |
| Filed May 31, 2011 |
| (SEC File No. 000-15502) |
Dear Mr. Spirgel,
This letter is written on behalf of our client, Comverse Technology, Inc. (the “Company”), in response to a comment letter to the Company, dated October 20, 2011 (the “Comment Letter”), from the Staff of the Securities and Exchange Commission (the “Commission”) relating to the Form 10-K for the fiscal year ended January 31, 2011, filed by the Company with the Commission on May 31, 2011 (the “Form 10-K”). For ease of reference, the comment is printed below in bold face and is followed by the Company’s response.
Controls and Procedures, page 118
| 1. | We note your response to comment three from our letter dated October 4, 2011. Please disclose management’s assessment of when the |
Securities and Exchange Commission
October 25, 2011
Page 2
| deficiencies in your disclosure controls and procedures and internal control over financial reporting will be corrected in your forthcoming Form 10-Q for the fiscal quarter ended October 31, 2011. |
The Company confirms that it will comply with the Staff’s comment by providing the requested disclosure in its forthcoming Form 10-Q for the fiscal quarter ending October 31, 2011.
* * *
Please do not hesitate to contact the undersigned at (212) 530-5003 if you have any questions or further comments regarding, or wish to discuss, any of the matters addressed in this letter.
Sincerely,
/s/ David E. Zeltner
| cc: | Celeste M. Murphy, Legal Branch Chief |
| Jessica Plowgian, Attorney-Advisor |
| Joel E. Legon, Senior Vice President and Interim Chief Financial Officer of Comverse Technology, Inc. |
| Shefali A. Shah, Senior Vice President, General Counsel and Corporate Secretary of Comverse Technology, Inc. |
