SCHEDULE 13G/A
0000919574-24-006496
0001167212
XXXXXXXX
LIVE
1
Common Stock, par value $0.10 per share
12/17/2024
0000023197
Comtech Telecommunications Corp
205826209
68 South Service Road
Suite 230
Melville
NY
11747
Rule 13d-1(c)
NEEDHAM INVESTMENT MANAGEMENT LLC
b
DE
0.00
1780000.00
0.00
1780000.00
1780000.00
N
6.11
IA
OO
Needham Asset Management, LLC
b
DE
0.00
1780000.00
0.00
1780000.00
1780000.00
N
6.11
HC
OO
Needham Aggressive Growth Fund
b
DE
0.00
1480000.00
0.00
1480000.00
1480000.00
N
5.08
IV
OO
George A. Needham
b
X1
0.00
1780000.00
0.00
1780000.00
1780000.00
N
6.11
HC
IN
Comtech Telecommunications Corp
305 N 54th Street, Chandler, Arizona 85226
Needham Investment Management L.L.C.
Needham Asset Management, LLC
Needham Aggressive Growth Fund
George A. Needham
Needham Investment Management L.L.C.
250 Park Avenue, 10th Floor
New York, New York 10117-1099
United States of America
Needham Asset Management, LLC
c/o Needham Investment Management L.L.C.
250 Park Avenue, 10th Floor
New York, New York 10117-1099
United States of America
Needham Aggressive Growth Fund
c/o Needham Investment Management L.L.C.
250 Park Avenue, 10th Floor
New York, New York 10117-1099
United States of America
George A. Needham
c/o Needham Investment Management L.L.C.
250 Park Avenue, 10th Floor
New York, New York 10117-1099
United States of America
Needham Investment Management L.L.C. - Delaware
Needham Asset Management, LLC - Delaware
Needham Aggressive Growth Fund - Delaware
George A. Needham - United States
Y
Needham Investment Management L.L.C. - 1,780,000
Needham Asset Management, LLC - 1,780,000
Needham Aggressive Growth Fund - 1,480,000
George A. Needham - 1,780,000
Needham Investment Management L.L.C. - 6.11%
Needham Asset Management, LLC - 6.11%
Needham Aggressive Growth Fund - 5.08%
George A. Needham - 6.11%
Needham Investment Management L.L.C. - 0
Needham Asset Management, LLC - 0
Needham Aggressive Growth Fund - 0
George A. Needham - 0
Needham Investment Management L.L.C. - 1,780,000
Needham Asset Management, LLC - 1,780,000
Needham Aggressive Growth Fund - 1,480,000
George A. Needham - 1,780,000
Needham Investment Management L.L.C. - 0
Needham Asset Management, LLC - 0
Needham Aggressive Growth Fund - 0
George A. Needham - 0
Needham Investment Management L.L.C. - 1,780,000
Needham Asset Management, LLC - 1,780,000
Needham Aggressive Growth Fund - 1,480,000
George A. Needham - 1,780,000
Y
N
All of the securities reported in this Schedule 13G are directly owned by advisory clients of Needham Investment Management L.L.C. None of those advisory clients, other than Needham Aggressive Growth Fund, may be deemed to beneficially own more than 5% of the Common Stock, $0.10 par value.
N
Please see Exhibit B attached hereto.
Y
Y
N
By signing below I certify that, to the best of my knowledge and belief, the securities referred to above were not acquired and are not held for the purpose of or with the effect of changing or influencing the control of the issuer of the securities and were not acquired and are not held in connection with or as a participant in any transaction having that purpose or effect, other than activities solely in connection with a nomination under ?? 240.14a-11.
Exhibit A - Joint Filing Agreement
Exhibit B - Control Person Identification
NEEDHAM INVESTMENT MANAGEMENT LLC
/s/ James W. Giangrasso
12/20/2024
Needham Asset Management, LLC
/s/ James W. Giangrasso
12/20/2024
Needham Aggressive Growth Fund
/s/ James W. Giangrasso
12/20/2024
George A. Needham
George A. Needham
12/20/2024
* Each Reporting Person disclaims beneficial ownership of the reported securities except to the extent of his, her or its pecuniary interest therein, and this report shall not be deemed an admission that such Reporting Person is the beneficial owner of the securities for purposes of Section 16 of the Securities Exchange Act of 1934, as amended, or for any other purpose.
To the extent that "ownership of 5 percent or less of a class" was indicated in Item 5, such response only applies to the Reporting Person(s) that indicated elsewhere herein that it beneficially owns five percent (5%) or less of the class.