SecProbe.io

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                         (COMPANY LETTERHEAD)

                                          May 24, 2005

Mr. Jay Webb (Mail Stop 0306)
Reviewing Accountant
Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549

Re:   Energy Conversion Devices, Inc.
      Form 10-K for fiscal year ended June 30, 2004
      Form 10-Q for the period ending December 31, 2004
      Your File No. 1-8403

Dear Mr. Webb:

      This letter is in response to your letter of May 9, 2005 sent to us via
facsimile on May 10, 2005. The information set forth below is numbered to
correspond to the paragraph of your letter.

FORM 10-K FOR THE PERIOD ENDING JUNE 30, 2004

Item 9A Controls and Procedures - Page 93
-----------------------------------------

1. We recognize your response to our Comment 6 and your willingness to revise
the ambiguity in future filings. However, we re-issue our comment. This matter
should be addressed via amendment to your Form 10-K for the Year Ended June 30,
2004.

    Response:

    We are removing the ambiguity in Item 9A as to the effectiveness of our
    disclosure controls and procedures and are stating that our disclosure
    controls and procedures were not effective for the gathering, analyzing and
    disclosing information required to be disclosed in connection with our
    Annual Report on Form 10-K for the year ended June 30, 2004.

    We are amending and restating Item 9A to our Form 10-K for the year ended
    June 30, 2004 via Form 10-K/A, Amendment No 1 filed contemporaneously
    herewith.

                                    * * * * *

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Mr. Jay Webb (Mail Stop 0306)
Securities and Exchange Commission
May 24, 2005
Page Two
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      ECD acknowledges that:

         o   it is responsible for the adequacy and accuracy of the disclosure
             in the filings,

         o   the staff comments or changes to disclosure in response to staff
             comments in the filings reviewed by the staff do not foreclose the
             Commission from taking any action with respect to the filing, and

         o   it may not assert staff comments as a defense in any proceeding
             initiated by the Commission or any person under the federal
             securities laws of the United States.

      If you have any additional questions or comments, please contact me at
(248) 299-6013.

                                            Sincerely,

                                            /s/ Stephan W. Zumsteg

                                            Stephan W. Zumsteg
                                            Chief Financial Officer

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