LARRY A. CERUTTI
                                                     Direct Dial: (714) 641-3450
                                                      E-mail: lcerutti@rutan.com


                         [Rutan & Tucker, LLP Letterhead]


                                December 27, 2006


VIA EDGAR CORRESPONDENCE
- ------------------------

Cecilia D. Blye, Chief
Office of Global Security Risk
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

     Re:  Emrise Corporation
          File No. 1-10346
          ------------------

Dear Ms. Blye:

     On behalf of our client, EMRISE Corporation (the "Company"), we are writing
in response to your letter dated December 20, 2006. We represented the Company
in connection with the negotiation of a credit facility with Wells Fargo
Business Credit and we were responsible for assisting the Company in its
preparation of various schedules to the credit and security agreement. The
reference to Iran within Schedule 5.11 is a scrivener's error made by an
associate of our firm. The Company has advised us that they have never conducted
business with or within the country of Iran.

     The serial number referred to in Schedule 5.11 is the United States Patent
and Trademark Office ("USPTO") Reference Number relating to the Company's
Approval of Certification in connection with the filing by the Company of an
Application for International Registration Governed Exclusively by the Madrid
Protocol (the "Application") with the USPTO. The Application, dated June 17,
2004, covered a number of countries, none of which is Iran. We note that
attorneys in our intellectual property practice group commonly refer to the
Application as the "IR." It appears that the associate in our corporate practice
group who was assisting the Company in the preparation of the schedules, and who
obtained information regarding the Company's patents and trademarks from a clerk
in our intellectual property practice group, misinterpreted the reference to
"IR" to mean Iran. Unfortunately, our client relied upon us to prepare this
portion of the schedule and, as a result, our client did not become aware of the
mistake until it received your letter.

     In connection with the foregoing response to your questions, the Company
acknowledges that:

     o    the Company is responsible for the adequacy and accuracy of the
          disclosure in the filings;




Cecilia D. Blye, Chief
December 27, 2006
Page 2


     o    staff comments or changes to disclosure in response to staff comments
          do not foreclose the Commission from taking any action with respect to
          the filings; and

     o    the Company may not assert staff comments as a defense in any
          proceeding initiated by the Commission on any person under the federal
          securities laws of the United States.

     We trust the foregoing is responsive to your inquiry. Should you have any
further questions or comments, please do not hesitate to call the undersigned at
(714) 641-3450.

                                       Sincerely yours,

                                       RUTAN & TUCKER, LLP

                                       /S/ LARRY A. CERUTTI

                                       Larry A. Cerutti

LAC:jss
cc:  Mr. Carmine T. Oliva (w/enc.)