SecProbe.io

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<TYPE>CORRESP
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ORBIT INTERNATIONAL CORP.
80 CABOT COURT
HAUPPAUGE, NY 11788
TELEPHONE: 631-435-8300
FAX #:     631-435-8458

                                        June  2,  2005

Ms.  Michele  Gohlke,  Branch  Chief
Division  of  Corporation  Finance
U.S.  Securities  and  Exchange  Commission
100  F  Street,  N.E.
Washington,  DC  20549

Re:  Comments  on  Form  10-KSB for the year ended December 31, 2004 and related
filings.
File  No.  000-03936

Dear  Ms.  Gohlke:
     Pursuant  to  your  letter dated May 23, 2005, enclosed is the supplemental
information  requested  in your comments.  Our responses have been keyed to your
comments  as  requested.

Form  10-KSB  for  the  Year  Ended  December  31,  2004
--------------------------------------------------------

Item  8A.  Controls  and  Procedures
------------------------------------

1.     During the three months ended December 31, 2004, there were no changes to
our  internal  control over financial reporting that has materially affected, or
is  reasonably  likely to materially affect, our internal control over financial
reporting.  We  will  revise  our  disclosure  in  future  filings.

Consolidated  Financial  Statements
-----------------------------------

Note  2.  Summary  of  Significant  Accounting  Policies
--------------------------------------------------------

2.     We  do  not  account  for  our  contracts using the guidance in SOP 81-1,
Accounting  for  Performance  of  Construction-Type  and Certain Production-Type
Contracts.  We have always maintained that the type of electronic components and
subsystems  that  we manufacture are not complex in nature and take a relatively
short  time  to  complete  and  ship.  Our  contracts  are generally for a large
quantity  of units at lower unit prices as opposed to very small quantities with
high  unit  prices.  In  addition,  the  contracts  we  receive  are  generally
short-term  in nature.  Consequently, we do not believe our contracts are within
the  scope  of the SOP.  As disclosed in our Significant Accounting Policies, we
record  our  revenue  when  units  are  completed  and shipped under a contract.

3.     All  of  our  contracts  are  for  products  made  to  specific  customer
specifications  with  no  right of return.  All of our units are tested prior to
shipment  by  our internal test department and in many cases, are inspected by a
customer  representative  prior to shipment from our facility.  All of our units
are  shipped with a one-year warranty.  Our units are returned from time to time
due  to  failure  in  the field, but in most instances at a time well beyond the
warranty  period (the customer would be invoiced for the repair).  Infrequently,
units  will  be  received  and  repaired  within the warranty period at no cost.
These  costs  have  been  immaterial  to date.  We will revise our disclosure in
future  filings.

Form  10-QSB  for  the  Quarter  Ended  March  31,  2005
--------------------------------------------------------

Notes  to  Condensed  Consolidated  Financial  Statements
---------------------------------------------------------

Note  4.  Cost  of  Sales
-------------------------

4.     The  costs  associated  with  all  of  our  shipments  are estimated on a
quarterly  basis  based  on  material  and  labor standards established for each
contract.  An  attrition  factor for material and a fatigue factor for labor are
also included.  Labor and overhead burden rates are actual rates determined on a
quarterly  basis  consistent  with  year-end.  This  method  complies  with GAAP
because  we  believe  it  provides  the most accurate measure of periodic income
during  an  interim  period.

Each  year,  we  make  true-up  adjustments  in  the fourth quarter based on our
physical inventory.  The true-up adjustment made in 2004 resulted in an increase
to gross profit of $97,000 and the true-up adjustment made in 2003 resulted in a
decrease  to  gross  profit  of  $3,000.  We do not consider these amounts to be
significant.

Forms  8-K  dated  March  3,  2005  and  May  5,  2005
------------------------------------------------------

5.     Future  filings  will  be  revised  accordingly.
6.     Future  filings  will  be  revised  accordingly.

In  addition  to  our  responses  above, the Company acknowledges the following:

a.     The  Company  is  responsible  for  the  adequacy  and  accuracy  of  the
disclosure  in  this  filing;
b.     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
c.     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.

If  you  have  any  questions  concerning  this  filing,  please  contact  me at
631-435-8300.

Very  truly  yours,
ORBIT  INTERNATIONAL  CORP.

/s/  Mitchell  Binder

Mitchell  Binder
Vice  President-Finance

Enclosure
cc:  Elliot  Lutzker,  Robinson  &  Cole  LLP

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