SecProbe.io

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<TYPE>LETTER
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      June 22, 2005

via U.S. mail and facsimile to (954) 917-2775

Mr. Howard L. Ehler, Jr.
Chief Executive Officer and Chief Financial Officer
Imperial Industries, Inc.
1259 Northwest 21st Street
Pompano Beach, FL  33069-1417

	RE:	Imperial Industries, Inc.
      Form 10-K for Fiscal Year Ended December 31, 2004
		Filed March 31, 2005
      File No. 001-07190

Dear Mr. Ehler:

		We have limited our review to only your financial
statements and related disclosures and do not intend to expand our
review to other portions of your document.   If you disagree with
a
comment, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
or may not raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Sources and Uses of Cash, page 17

1. Include your interest commitments under your interest-bearing
debt
in this table, or provide textual discussion of this obligation
below
the table.  If you provide a textual discussion, the discussion
should quantify the interest payments using the same time frames
stipulated in the table.  Refer to footnote 46 to Release 33-8350
"Interpretation:  Commission Guidance Regarding Management`s
Discussion and Analysis of Financial Condition and Results of
Operations."

(o) Segment Reporting, page 31

2. You indicate that you operate in a single operating segment.
However, we note, based on your discussion in Item 1 of your Form
10-
K, that you manufacture product through Premix-Marbletite
Manufacturing Co. and Acrocrete, Inc. and you distribute your own
and
complementary products through Just-Rite Supply, Inc.  Please
define
your operating segment for us.  Please clarify for us whether your
business includes any components that meet the definition of an
operating segment in paragraph 10 of SFAS No. 131.  If so, please
tell us how you meet the aggregation requirements in paragraph 17
if
SFAS No. 131, given the nature of your manufacturing and
distribution
businesses.  In addition, please provide us with the reports
regularly reviewed by the Chief Operating Decision Maker (CODM),
so
we can better understand your determination that you only have one
reportable segment.

(13) Commitments and Contingencies, page 40

3. In a supplemental response, please explain to us why you cannot
estimate your exposure in these lawsuits if you are currently the
defendants in 62 lawsuits. Tell us also whether you are aware of
developments in any comparable product liability cases that may be
relevant for purposes of estimating probable loss, or reasonably
possible loss, pursuant to SFAS 5. Please provide additional
disclosures in your future filings as addressed in SAB Topic 5:Y
to
allow the readers of your financial statements to assess your
exposure and likelihood of a material loss as a result of these
lawsuits.  Such disclosure should include the aggregate amount
that
you are being sued for on the cases that your insurance carriers
have
taken responsibility compared to the remaining cases that they
have
not.  You should also disclose the amount of insurance coverage
that
you maintain.  Finally, you should disclose if you are still
selling
these same products that have resulted in these lawsuits.

Selected Quarterly Financial Data

4. In future filings, please disclose the required quarterly
financial data contained in Item 302 of Regulation S-K.

*    *    *    *

		Please respond to these comments within 10 business
days,
or tell us when you will provide us with a response.  Please
provide
us with a supplemental response letter that keys your responses to
our comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review.  Please file your
supplemental response on EDGAR as a correspondence file.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company 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.

		In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.

      If you have any questions regarding these comments, please
direct them to Ryan Rohn, Staff Accountant, at (202) 551-3739 or,
in
his absence, to Al Pavot, Staff Accountant, at (202) 551-3738, or
to
the undersigned at (202) 551-3255.

							Sincerely,

							Nili Shah
							Accounting Branch Chief
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Mr.  Howard L. Ehler, Jr.
Imperial Industries, Inc.
June 22, 2005
Page 2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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