ITUS CORPORATION
12100 Wilshire Boulevard, Suite 1275
Los Angeles, CA 90025
September 16, 2015
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attn: Mark P. Shuman
Re:
ITUS Corporation
Registration Statement on Form S-3
File No. 333-206782
Dear Mr. Shuman:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, ITUS Corporation (the Company) hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 4:00 p.m. Eastern Standard Time on Friday, September 18, 2015, or as soon as practicable thereafter.
Please note that we acknowledge the following:
·
should the Securities and Exchange Commission (the Commission) or the staff (the Staff), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
·
the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
·
the Company may not assert Staff comments and the declaration of effectiveness 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/ Robert A. Berman
Name: Robert A. Berman
Title: President and Chief Executive Officer