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Timothy P. Scanlan
Mestek,
Inc.

413-564-5849

June 21, 2005

VIA EDGAR TRANSMISSION

Ms. Jennifer Hardy

Legal Branch Chief
Division Of Corporation Finance
Securities
and Exchange Commission
 450 Fifth Street, N.W.
Washington, D.C. 20549
Mail

Stop: 0304

Re:
Mestek, Inc.
 Schedule
14C filed April 29, 2005
 Form 10-K filed March 31, 2005
         File
No. 001-00448

Omega
Flex, Inc.
Form 10 filed April 29, 2005
      File
No. 001-32849

Dear Ms. Hardy:

        On
behalf of Mestek, Inc., a Pennsylvania corporation (“Mestek”) and Omega Flex,
Inc., a Pennsylvania corporation (the “Registrant” or “Omega”), we
transmit herewith for filing with the Securities and Exchange Commission (the
“Commission”) pursuant to Rules 101(a)(i) and (iii) of Regulation S-T under the
Commission’s Electronic Data Gathering and Retrieval System, and Section 6 of
Regulation C under the Securities Act of 1933, as amended (the “Securities
Act”): (i) the Registrant’s Registration Statement on Form 10, No. 001-_______
(the “Form 10”), and (ii) Mestek’s revised preliminary information
statement (the “Information Statement”) relating to the distribution of its
shares of Omega to its stockholders, as described therein.

        We
are providing you with responses to the comments received from the Commission’s Staff
(the “Staff”) by letter dated May 25, 2005 (the “Comment Letter”),
with respect to the Registrant’s Registration Statement on Form 10, No. 001-32849
(together with all exhibits thereto) (the “Filed Form 10”), the Information
Statement, and Mestek’s Form 10-K filed March 31, 2005, File No. 001-00448. For the
Staff’s convenience, the Staff’s comments have been restated below in bold type
(the numbers thereof corresponding to the numbers of the Staff’s comments contained
in the Comment Letter) and Mestek’s and the Registrant’s responses have been set
forth below in italics. The Form 10 reflects the Registrant’s responses to the
Comment Letter. For the further convenience of the Staff, to the extent there have
occurred pagination changes with respect to certain text contained in the Information
Statement filed with the Commission on April 29, 2005, we have indicated the new page
numbers on which the beginning of such revised text now appears in the Information
Statement. All capitalized terms used and not defined herein have the respective meanings
assigned to them in the Comment Letter.

        Courtesy
copies of this letter and of the Form 10 together with all exhibits and supplemental Staff
information, are being concurrently provided via Federal Express overnight delivery
directly to the attention of Ms. Jennifer Hardy and Mr. Andrew Schoeffler.

SCHEDULE 14C FILED
APRIL 29, 2005

General

1.
    Please
update the capitalization table, the selected historical financial and
          operating data, the unaudited pro forma financial statements, the
          management’s discussion and analysis of financial condition and results of
          operations, and the financial statements for financial information as of and
for           the three months ended March 31, 2005. In addition, please update all other
          disclosures as of the most recent practicable date, including, for example and
          without limitation, the security ownership table.

Pursuant to the Staff’s
request, Mestek and Omega have updated the capitalization table, the selected historical
financial and operating data, the unaudited pro forma financial statements, the
management’s discussion and analysis of financial condition and results of
operations, and the financial statements for the three months ended March 31, 2005. Mestek
and Omega have also updated all other disclosures as of the most recent practicable date.

2.
    Please
disclose the information required by Item 3 of Schedule 14C.

Pursuant to the Staff’s
request, Mestek has updated the relevant sections of the Information Statement to include
disclosure describing the interest of certain persons in or opposition to matters to be
acted upon on page 70.

          3.

          It appears that Mestek appointed a special committee of directors to review
          the spin-off of Omega Flex,  which was first proposed by Mr. John E.
          Reed. Please expand the disclosure in the filing to discuss the
          selection of this committee and its findings. In this regard, we note that
          the current disclosure in  the filing only discusses the findings of the
          full board.

The appointment of a special
committee of the Mestek board of directors was done in response by a proposal by John E.
Reed, Chief Executive Officer of Mestek, for Mestek to effect a reverse stock split
thereby reducing the number of Mestek shareholders to less than 300, and immediately
thereafter make appropriate filings to suspend Mestek’s obligations to file reports
with the SEC and delist the common stock from the New York Stock Exchange (“going
private”). The special committee was appointed by the full board to evaluate the
management proposal for the going private transaction, and to determine an approach to the
proposed transation that would be in the best interests of the Mestek shareholders, and
negotiate appropriate terms and conditions of the going private transaction. The special
committee has not been charged with any responsibility for reviewing the distribution or
the terms and conditions thereof. However, the special committee has some interest in the
value of the Omega common stock, but only as it relates to the going private transaction
in terms of the value of the Mestek common stock after the distribution. The full Mestek
board has approved the distribution as described in the information statement and in the
separation and distribution agreement between Mestek and Omega which is attached as an
exhibit to the information statement.

Cover Page of Schedule
14C

          4.

          Please disclose the amount on which the filing fee was calculated and the
          method by which the  transaction value was calculated.

Mestek advises the Staff that the
filing fee was calculated in error based upon the proposed market price of $5.00
multiplied by the number of shares to which this transaction applies 10,100,120. Per
Exchange Act Rule 0-11, because there is no prior market price for the securities being
registered, the filing fee should instead be computed based on the book value ($0.67) of
the securities as of the latest practicable date which would result in a filing fee of
$1,765.50.

Cover Page of
Information Statement

          5.

          We note the disclosure in the second sentence of the third paragraph. Please
          revise this disclosure to  provide it in the form required by Item 2 of
          Schedule 14C.

Mestek advises the Staff that it
has revised the referenced text to the form required by Item 2 of Schedule 14C.

          6.

          We note the disclosure here and in the two letters to security holders that
          Omega Flex’s common stock  has been authorized to be listed on the
          NASDAQ National Market. We also note the disclosure contained  elsewhere
          in the filing that Omega Flex has merely applied to have its common stock listed
          on the NASDAQ  National Market. See, for example and without limitation,
          the sections entitled “Summary of the  Distribution — Stock
          Exchange Listing” and “Description of Capital Stock — NASDAQ
          National Market  Listing.” Please revise accordingly.

Mestek advises the Staff that it
has revised the cover page and two letters to security holders to make them consistent
with the information statement that Omega Flex has applied for a listing in the NASDAQ
National Market.

7.
    Please
disclose up front that 14% of the company will be owned by executive           officers.

Mestek advises the Staff that it
has revised the cover page of the information statement to disclose this information.

8.
    Please
briefly explain “when issued” trading and           “regular-way” trading.

Mestek advises the Staff that it
has revised page 3 of the Information Statement to explain “when issued” trading

and
“regular-way” trading.

Table of Contents

          9.

          Please revise to include a listing of all agreements and other exhibits that
          will be delivered to  security holders with the information statement.

Mestek advises the Staff that it
has filed or will file all materials agreements and exhibits with the Form 10.

Questions and Answers
About the Distribution Summary of the Distribution

          10.

          Please revise to eliminate information that is repeated in the Q&A
          section and the summary section. For  purposes of eliminating
          redundancies and grouping like information together please view the Q&A and
           summary as one section. In addition, when revising this disclosure, we
          strongly suggest that the  procedural questions be discussed with short,
          clear answers in the Q&A and that the material,  substantive
          disclosure be placed in the summary.

Mestek advises the Staff that it
has revised the information statement by eliminating redundancies in the summary section
and the Q&A section, by moving all substantive information to the summary section, by
relocating the Q&A section to follow the summary, and by including procedural
questions in the Q&A with short, clear answers. We believe that this presentation
gives appropriate prominence to the summary section, and provides context to the
information in the following Q&A section.

          11.

          Please tell us supplementally of the basis for your statement that you are a
          “leading” manufacturer of  flexible metal hose.

Mestek and Omega advises the Staff
that in the flexible gas piping market, the U.S. market is currently concentrated in the
residential housing market, and based on the reports issued by the national trade groups
on housing construction, the level of acceptance of flexible gas piping in the
construction market, and the average usage of flexible gas piping in a residential
building, we are able to estimate with a high level of accuracy the size of the total gas
piping market, and based on our sales our position within that market. For other
applications, industry trade groups collect and report on the size of the relevant market,
and we can estimate our percentage of the relevant market based on our sales as compared
to the market as a whole. Furthermore, the customer base for the products we sell
is widely known, as is which manufacturer is aligned with which customers. Independent
manufacturers sales representatives have good estimates and in many cases, factual
information on the volume of purchases of customers in their territories. Because there
are gross differences in the market shares of many of the competing manufacturers, it is
possible to reasonably assess shared positions. Large national accounts also have a sense
as to shared positions as well, because they have relationships with most of the competing
manufacturers and will share opinions. Lastly, the term “leading” implies a host
of issues other than sales volume and share position. This includes the range and
capability of the product line, history of product development and new product launches,
all of which is in public domain. Based on this alone, Omega Flex is without question the
undisputed leader in at least one of the two major market segments in which it
participates.

Settlement of
Intercompany Receivable and Payment of Dividends to Mestek

          12.

          Please clarify here and, as appropriate, elsewhere in the filing that the
          dividend will be paid to  Mestek and the management security holders. In
          addition, it appears that Omega Flex will finance this  dividend by
          incurring indebtedness. Please disclose here and, as appropriate, elsewhere in
          the filing  the terms of this indebtedness. In this regard, we note the
          disclosure in the section entitled  “Relationships Between Our
          Company and Mestek, Inc. – Mestek Dividend.”

Mestek advises the Staff that it
has revised this disclosure to make clear that the dividend will be paid to Mestek and the
management security holders. However, as disclosed in the amended information statement,
the dividend will not be financed through the incurrence of debt; rather the dividend will
be funded by a payment by Mestek of a portion of the intercompany receivable owed to
Omega. This amount will be used to pay the dividend, 86% to Mestek and 14% to the
management shareholders. This arrangement will reduce – but not eliminate – the
amount of the intercompany account receivable owed by Mestek to Omega.

          13.

          Please describe in greater detail here and, as appropriate, elsewhere in the
          filing the terms of the  intercompany receivable that Mestek owes Omega
          Flex and how this receivable will be repaid upon  completion of the
          distribution.

We have revised the information
statement, both here and elsewhere to show the terms of the account receivable owed by
Mestek to Omega, and the terms of the repayment thereof.

Incurrence of Debt

          14.

          Please disclose the aggregate amount that Omega Flex anticipates will be
          available under its credit  facility.

Pursuant to the Staff’s
request, we have revised the information statement to disclose that most if not all of
aggregate amount of Omega’s expected $5 million credit facility will be available
under its terms after the effective date of the distribution.

Risk Factors

          15.

          Many of the risk factors could apply to any issuer. See, for example and
          without limitation, risk  factors three, thirteen, fourteen, fifteen,
          seventeen, nineteen and twenty two. Please clearly explain  how they
          apply to Omega Flex.

Pursuant to the Staff’s
request, Mestek has revised the third, thirteenth, fourteenth, fifteenth and nineteenth
risk factors to more clearly explain how such risk factors apply to Omega Flex and has
deleted the seventeenth and twenty second risk factors as such risk could apply to any
issuer.

We may substantially
increase our debt in the future

          16.

          Please disclose the amount of debt that Omega Flex will have outstanding as
          of the completion of the  distribution.

Pursuant to the Staff’s
request on page 14, we have revised the information statement to disclose that Omega will
have about $3 million of debt outstanding as of the completion of the distribution, which
debt was incurred prior to the distribution for an unrelated purpose.

The agreements we are
entering into with Mestek in connection with the distribution...

          17.

          Place clarify that these agreements may be less favorable to Omega Flex than
          either its previous  agreements with Mestek or what it could have
          obtained in arm’s length negotiations with unaffiliated  third
          parties.

Pursuant to the Staff’s
request on page 17 and 76, Mestek has clarified that the agreements that Omega Flex is
entering into with Mestek in connection with the distribution may be less favorable to
Omega Flex than either its previous agreements with Mestek or what it could have obtained
in arm’s length negotiations with unaffiliated third parties.

Our charter documents or
agreements may delay or prevent a change in control

          18.

          Please briefly discuss the provisions of Omega Flex’s charter documents
          that may delay or prevent a  change in control. In this regard, we note
          the disclosure in the section entitled “Description of  Capital
          Stock – Anti-Takeover Previsions.” In addition, please clearly state
          the risk, namely that  these anti-takeover provisions may preve