[LETTERHEAD OF
SONNENSCHEIN NATH & ROSENTHAL LLP]
| |
101
JFK Parkway
Short
Hills, NJ 07078-2708
973.912.7100
973.912.7199
fax
www.sonnenschein.com
|
Roland
S. Chase
973.912.7179
rchase@sonnenschein.com
July 9,
2009
VIA
EDGAR
Securities
and Exchange Commission
Mail Stop
4561
100 F
Street, N.E.
Washington,
D.C. 20549
Attention:
Tamara Tangen
Division
of Corporate Finance
|
Re:
|
Wayside
Technology Group, Inc. (the “Company”)
Form
10-K for the Year Ended December 31, 2008
Form
10-Q For the Quarterly Period Ended March 31, 2009
File
No. 000-26408
|
Dear Ms.
Tangen:
During our telephone conversation of
July 7, 2009, you had asked for clarification on the Company’s response,
submitted via EDGAR on June 15, 2009, with respect to comment #1 contained in
your letter dated May 18, 2009. As discussed, please find below the
revised disclosure proposed by the Company to be included in its future filings,
which replaces the Company’s previous response to such comment:
Evaluation of Disclosure Controls
and Procedures. As required by Rule 13a-15(b) under the Exchange Act, our
management carried out an evaluation of the effectiveness of the design and
operation of the Company’s “disclosure controls and procedures”, as such term is
defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act, as of the end
of the period covered by this report. This evaluation was carried out
under the supervision and with the participation of our management, including
our Company’s President, Chairman of the Board and Chief Executive Officer
(principal executive officer) and Vice President and Chief Accounting Officer
(principal financial officer). Based upon that evaluation, the Company’s Chief
Executive Officer and Chief Accounting Officer concluded that the Company’s
disclosure controls and procedures were effective, as of the end of the period
covered by this report, to ensure that information required to be disclosed by
the Company in the reports it files or submits under the Exchange Act is
recorded, processed, summarized and reported within the time periods specified
in the Securities and Exchange Commission’s rules and forms and is accumulated
and communicated to the Company’s management, including the Company’s Chief
Executive Officer and Chief Accounting Officer, as appropriate, to allow timely
decisions regarding required disclosure.
If you
have any questions, or if we may be of any assistance, please do not hesitate to
contact the undersigned at (973) 912-7179.
Sincerely,
/s/
Roland S. Chase
Roland S.
Chase
Associate
cc: Mr.
Simon F. Nynens
Mr. Kevin T. Scull