[Letterhead of Thompson Hine LLP]
May 19, 2016
By EDGAR and Electronic Mail
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Mergers and Acquisitions
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Bryan J. Pitko Attorney Advisor |
| RE: | Rubicon Technology, Inc. (“Rubicon”) Revised Preliminary Proxy Statement on Schedule 14A |
Filed May 18, 2016 by Paragon Technologies, Inc., et al.
File No. 001-33834
Dear Mr. Pitko,
On behalf of Paragon Technologies, Inc., GAD Partners Fund LP, GAD Capital Management LLC, Hesham M. Gad, Jack H. Jacobs, Deborah R. Mertz and Samuel S. Weiser (each, a “Filing Person” and collectively, the “Filing Persons”), we are responding to your additional comments provided to us orally on May 18, 2016 in connection with the revised preliminary proxy statement on Schedule 14A filed by the Filing Persons on May 18, 2016 (the “Proxy Statement”). Based on our discussions with you on May 18, 2016, the Proxy Statement has been revised to incorporate your additional comments and is being filed via EDGAR today.
The Filing Persons’ acknowledgement follows on the next page. Please direct any questions to me at (216) 566-5527 orDerek.Bork@ThompsonHine.com.
Respectfully,
/s/ Derek D. Bork
Derek D. Bork
Each of the undersigned hereby acknowledges that (i) the Filing Person is responsible for the adequacy and accuracy of the disclosure in the filing; (ii) staff comments or changes to disclosure in response to staff comments do not foreclose the Securities and Exchange Commission (the “Commission”) from taking any action with respect to the filing; and (iii) the Filing Person may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Dated: May 19, 2016
PARAGON TECHNOLOGIES, INC
/s/ Hesham M. Gad
Hesham M. Gad
Chief Executive Officer
GAD PARTNERS FUND LP,
by GAD Capital Management LLC, its general partner
s/ Hesham M. Gad
Hesham M. Gad
Managing Partner
GAD CAPITAL MANAGEMENT LLC
s/ Hesham M. Gad
Hesham M. Gad
Managing Partner
S/ HESHAM M. GAD
HESHAM M. GAD
/S/ JACK H. JACOBS
JACK H. JACOBS
/S/ DEBORAH R. MERTZ
DEBORAH R. MERTZ
/S/ SAMUEL S. WEISER
SAMUEL S. WEISER
