August 23, 2006
Attention: Larry Spirgel
Securities and Exchange Commission
Mailstop 3720
100 F Street N.E.
Washington, D.C. 20549
  Request for Withdrawal of Registration Statement on Form S-4
  File Number 333-135424 (the “Registration Statement”)
Dear Mr. Spirgel:
     Pursuant to Rule 477 under the Securities Act of 1933, as amended, ADC Telecommunications, Inc. (the “Company”) hereby makes application to withdraw the Registration Statement relating to its common stock, par value $0.20 per share, and the attached Rights to Purchase Shares of Series A Junior Participating Preferred Stock. On August 9, 2006, the Company and Andrew Corporation announced that they have terminated the proposed business combination to which the Registration Statement relates. The Company represents that no securities have been sold under the Registration Statement and all activity in pursuit of the public offering has been discontinued.
     Accordingly, we request an order granting the withdrawal of the Registration Statement be issued by the Securities and Exchange Commission as soon as possible. Should you have any questions regarding this matter, please contact Robert A. Rosenbaum of Dorsey & Whitney LLP at (612) 340-2600.
Very truly yours,
ADC Telecommunications, Inc.
By:   /s/ Gokul V. Hemmady    
  Name:   Gokul V. Hemmady   
  Title:   Vice President, Chief Financial Officer   
  Paul Fischer, Securities and Exchange Commission
  Robert A. Rosenbaum, Dorsey & Whitney LLP
  James T. Lidbury, Mayer, Brown, Rowe & Maw LLP