PHAZAR CORP
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101 S.E. 25th Avenue   o   Mineral Wells, Texas 76067
(940) 325-3301  o  Fax (940) 325-0706

March 4, 2010

Mr. Larry Spirgel
Assistant Director
Division of Corporation Finance
United States Securities and Exchange Commission
Washington, DC 20549

         Re:      PHAZAR CORP
                  Form 10-K for the Fiscal Year ended May 31, 2009
                  Filed  August 14, 2009
                  File No. 000-12866

Dear Mr. Spirgel:

In response to your letter  dated  February  22,  2010,  PHAZAR CORP submits the
following responses to your comments. Our responses are in italics.

Form 10-K for Fiscal Year ended May 31, 2009
Item 9A Controls and Procedures, page 39

1.            It appears that you have combined your disclosures on controls and
              procedures with your evaluation of internal control over financial
              reporting.  In this regard we note that you  included a conclusion
              on our  disclosure  controls and  procedures but we did not find a
              conclusion on your  evaluation of internal  control over financial
              reporting.  Please  amend your 10-K to include a  statement  as to
              whether or not internal  controls  over  financial  reporting  are
              effective. Refer to Item 307 and 308T of Regulation SK.

The Company has filed an Amended Form 10-K concurrent with this letter which, in
Item 9A,  separates out its statements  about  internal  controls over financial
reporting and disclosure  controls and procedures  into separate  paragraphs and
concludes  that  our  assessment  concluded  that  our  internal  controls  over
financial reporting were effective as of May 31, 2009.

PHAZAR CORP acknowledges that it is responsible for the adequacy and accuracy of
its  disclosure in its Commission  filings,  that  Commission  staff comments or
changes to disclosure in response to Commission  staff comments do not foreclose
the  Commission  from taking any action with respect to the filings;  and it may
not assert Commission staff comments as a defense in any proceeding initiated by
the  Commission  or any person under the federal  securities  laws of the United
States.


                                       Very truly yours,

                                       /s/DEBORAH INZER

                                       Deborah Inzer
                                       Vice-President and
                                       Chief Financial Officer