Needham entities report 4% Comtech (CMTL) stake in amended ownership filing

Rhea-AI Filing Summary

Comtech Telecommunications Corp. (CMTL) received an updated ownership report from Needham entities. Needham Investment Management, Needham Asset Management, Needham Aggressive Growth Fund and George A. Needham together report beneficial ownership of up to 1,174,300 shares of common stock, representing 4.0% of the class. The Needham Aggressive Growth Fund directly holds 1,019,500 shares, or 3.4% of the outstanding common stock.

The filing states that all reported shares are directly owned by advisory clients of Needham Investment Management, and no individual advisory client is deemed to own more than 5% of the stock. The reporting persons certify the holdings are not intended to change or influence control of Comtech.

SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

SCHEDULE 13G

UNDER THE SECURITIES EXCHANGE ACT OF 1934

(Amendment No. 2)

COMTECH TELECOMMUNICATIONS CORP. /DE/

(Name of Issuer)

Common Stock, par value $0.10 per share

(Title of Class of Securities)

205826209

(CUSIP Number)

12/31/2025

(Date of Event Which Requires Filing of this Statement)

Check the appropriate box to designate the rule pursuant to which this Schedule is filed:

Rule 13d-1(b)

Rule 13d-1(c)

Rule 13d-1(d)

SCHEDULE 13G

CUSIP No. 205826209

1

Names of Reporting Persons

NEEDHAM INVESTMENT MANAGEMENT L.L.C.

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

DELAWARE

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 0.00
6	Shared Voting Power 1,174,300.00
7	Sole Dispositive Power 0.00
8	Shared Dispositive Power 1,174,300.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

1,174,300.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

4.0 %

12

Type of Reporting Person (See Instructions)

IA, OO

SCHEDULE 13G

CUSIP No. 205826209

1

Names of Reporting Persons

NEEDHAM ASSET MANAGEMENT, LLC

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

DELAWARE

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 0.00
6	Shared Voting Power 1,174,300.00
7	Sole Dispositive Power 0.00
8	Shared Dispositive Power 1,174,300.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

1,174,300.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

4.0 %

12

Type of Reporting Person (See Instructions)

HC, OO

SCHEDULE 13G

CUSIP No. 205826209

1

Names of Reporting Persons

NEEDHAM AGGRESSIVE GROWTH FUND

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

DELAWARE

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 0.00
6	Shared Voting Power 1,019,500.00
7	Sole Dispositive Power 0.00
8	Shared Dispositive Power 1,019,500.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

1,019,500.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

3.4 %

12

Type of Reporting Person (See Instructions)

IV, OO

SCHEDULE 13G

CUSIP No. 205826209

1

Names of Reporting Persons

GEORGE A. NEEDHAM

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

UNITED STATES

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 0.00
6	Shared Voting Power 1,174,300.00
7	Sole Dispositive Power 0.00
8	Shared Dispositive Power 1,174,300.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

1,174,300.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

4.0 %

12

Type of Reporting Person (See Instructions)

HC, IN

SCHEDULE 13G

Item 1.
(a)	Name of issuer: COMTECH TELECOMMUNICATIONS CORP. /DE/
(b)	Address of issuer's principal executive offices: 305 N 54th Street, Chandler, Arizona 85226
Item 2.
(a)	Name of person filing: Needham Investment Management L.L.C. Needham Asset Management, LLC Needham Aggressive Growth Fund George A. Needham
(b)	Address or principal business office or, if none, residence: 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
(c)	Citizenship: Needham Investment Management L.L.C. - Delaware Needham Asset Management, LLC - Delaware Needham Aggressive Growth Fund - Delaware George A. Needham - United States
(d)	Title of class of securities: Common Stock, par value $0.10 per share
(e)	CUSIP No.: 205826209
Item 3.	If this statement is filed pursuant to §§ 240.13d-1(b) or 240.13d-2(b) or (c), check whether the person filing is a:
(a)	Broker or dealer registered under section 15 of the Act (15 U.S.C. 78o);
(b)	Bank as defined in section 3(a)(6) of the Act (15 U.S.C. 78c);
(c)	Insurance company as defined in section 3(a)(19) of the Act (15 U.S.C. 78c);
(d)	Investment company registered under section 8 of the Investment Company Act of 1940 (15 U.S.C. 80a-8);
(e)	An investment adviser in accordance with § 240.13d-1(b)(1)(ii)(E);
(f)	An employee benefit plan or endowment fund in accordance with § 240.13d-1(b)(1)(ii)(F);
(g)	A parent holding company or control person in accordance with § 240.13d-1(b)(1)(ii)(G);
(h)	A savings associations as defined in Section 3(b) of the Federal Deposit Insurance Act (12 U.S.C. 1813);
(i)	A church plan that is excluded from the definition of an investment company under section 3(c)(14) of the Investment Company Act of 1940 (15 U.S.C. 80a-3);
(j)	A non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J). If filing as a non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J), please specify the type of institution:
(k)	Group, in accordance with Rule 240.13d-1(b)(1)(ii)(K).
Item 4.	Ownership
(a)	Amount beneficially owned: Needham Investment Management L.L.C. - 1,174,300 Needham Asset Management, LLC - 1,174,300 Needham Aggressive Growth Fund - 1,019,500 George A. Needham - 1,174,300
(b)	Percent of class: Needham Investment Management L.L.C. - 4.0% Needham Asset Management, LLC - 4.0% Needham Aggressive Growth Fund - 3.4% George A. Needham - 4.0%
(c)	Number of shares as to which the person has:
	(i) Sole power to vote or to direct the vote: Needham Investment Management L.L.C. - 0 Needham Asset Management, LLC - 0 Needham Aggressive Growth Fund - 0 George A. Needham - 0
	(ii) Shared power to vote or to direct the vote: Needham Investment Management L.L.C. - 1,174,300 Needham Asset Management, LLC - 1,174,300 Needham Aggressive Growth Fund - 1,019,500 George A. Needham - 1,174,300
	(iii) Sole power to dispose or to direct the disposition of: Needham Investment Management L.L.C. - 0 Needham Asset Management, LLC - 0 Needham Aggressive Growth Fund - 0 George A. Needham - 0
	(iv) Shared power to dispose or to direct the disposition of: Needham Investment Management L.L.C. - 1,174,300 Needham Asset Management, LLC - 1,174,300 Needham Aggressive Growth Fund - 1,019,500 George A. Needham - 1,174,300
Item 5.	Ownership of 5 Percent or Less of a Class.
	Ownership of 5 percent or less of a class
Item 6.	Ownership of more than 5 Percent on Behalf of Another Person.
	If any other person is known to have the right to receive or the power to direct the receipt of dividends from, or the proceeds from the sale of, such securities, a statement to that effect should be included in response to this item and, if such interest relates to more than 5 percent of the class, such person should be identified. A listing of the shareholders of an investment company registered under the Investment Company Act of 1940 or the beneficiaries of employee benefit plan, pension fund or endowment fund is not required. 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 may be deemed to beneficially own more than 5% of the Common Stock, $0.10 par value.
Item 7.	Identification and Classification of the Subsidiary Which Acquired the Security Being Reported on by the Parent Holding Company or Control Person.
	If a parent holding company has filed this schedule, pursuant to Rule 13d-1(b)(ii)(G), so indicate under Item 3(g) and attach an exhibit stating the identity and the Item 3 classification of the relevant subsidiary. If a parent holding company has filed this schedule pursuant to Rule 13d-1(c) or Rule 13d-1(d), attach an exhibit stating the identification of the relevant subsidiary. Please see Exhibit B attached hereto.
Item 8.	Identification and Classification of Members of the Group.
	Not Applicable
Item 9.	Notice of Dissolution of Group.
	Not Applicable

Item 10.

Certifications:

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.

SIGNATURE

After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete and correct.

NEEDHAM INVESTMENT MANAGEMENT L.L.C.

Signature:	By: /s/ James W. Giangrasso
Name/Title:	James W. Giangrasso, Chief Financial Officer
Date:	02/13/2026

NEEDHAM ASSET MANAGEMENT, LLC

Signature:	By: /s/ James W. Giangrasso
Name/Title:	James W. Giangrasso, Authorized Person
Date:	02/13/2026

NEEDHAM AGGRESSIVE GROWTH FUND

Signature:	By: /s/ James W. Giangrasso
Name/Title:	James W. Giangrasso, Chief Financial Officer
Date:	02/13/2026

GEORGE A. NEEDHAM

Signature:	By: /s/ George A. Needham
Name/Title:	George A. Needham
Date:	02/13/2026

Comments accompanying signature: * 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.

Exhibit Information

Exhibit A - Joint Filing Agreement Exhibit B - Control Person Identification

FAQ

What ownership stake in Comtech Telecommunications (CMTL) do the Needham entities report?

The Needham entities report beneficial ownership of up to 1,174,300 shares of Comtech common stock, representing 4.0% of the outstanding class. This includes shares held through advisory clients of Needham Investment Management, which retains shared voting and dispositive power over those holdings.

How many Comtech (CMTL) shares does Needham Aggressive Growth Fund hold?

Needham Aggressive Growth Fund reports beneficial ownership of 1,019,500 Comtech shares, representing 3.4% of the company’s common stock. These shares are held with shared voting and dispositive power, as disclosed in the Schedule 13G/A amendment filed with the SEC.

Do the Needham entities seek to influence control of Comtech (CMTL)?

The reporting persons certify that the Comtech securities were not acquired and are not held to change or influence control of the issuer. They also state the holdings are not in connection with any transaction having that purpose or effect, other than certain nomination activities referenced in the certification.

Who are the reporting persons in the Comtech (CMTL) Schedule 13G/A filing?

The filing lists Needham Investment Management L.L.C., Needham Asset Management, LLC, Needham Aggressive Growth Fund, and George A. Needham as reporting persons. Each reports beneficial ownership and shared voting and dispositive power over specified amounts of Comtech common stock.

Are Comtech (CMTL) shares held directly by Needham or by its clients?

The filing explains that all reported Comtech shares are directly owned by advisory clients of Needham Investment Management L.L.C.. The reporting persons disclaim beneficial ownership beyond any pecuniary interest, and no single advisory client is deemed to own more than 5% of the common stock.

What percentage of Comtech (CMTL) does Needham Aggressive Growth Fund own?

Needham Aggressive Growth Fund reports owning 3.4% of Comtech’s common stock, corresponding to 1,019,500 shares. The fund has shared voting and shared dispositive power over these shares, according to the Schedule 13G/A amendment filed with the SEC.