SecProbe.io

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Via Edgar and Overnight Mail

February 7, 2008

Barbara C. Jacobs, Esq.
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549
Mail Stop 4561

Re:  Park Electrochemical Corp.
     Form 10-K for the fiscal year ended February 25, 2007
     Filed May 10, 2007
     File No. 001-04415

Dear Ms. Jacobs:

We have  reviewed  the  comments  relating  to  the  above
referenced filing presented in the letter signed by you  and
dated January 30, 2008 to Mr. Brian E. Shore, President  and
Chief   Executive  Officer  of  Park  Electrochemical  Corp.
(hereinafter  "Park" or the "Company").   The  comments  and
Park's responses to the comments are set forth below:

Form 10-K for the Fiscal Year Ended February 25, 2007

Part I

Item 1. Business, page 4

COMMENT:

     1. It  appears that Sanmina-SCI Corporation, and TTM
       Technologies, Inc. represent 16.7% and 10.7%, respectively,
       of your total worldwide sales of printed circuit materials
       in FY 2007.  We also note your risk factor disclosure on
       page 17 that a loss of one or more of your key customers
       could affect your business.  Because you appear to be
       substantially dependent on your agreements with Sanmina-SCI
       Corporation, and TTM Technologies, Inc., please advise if
       you considered including in your Form 10-K a description of
       your contractual arrangements with these customers and
       filing your agreements with them as exhibits.  See Item
       601(b)(10)(ii)(B) of Regulations S-K.

RESPONSE:

The  Company  does  not have contractual  arrangements  with
these   customers.   The  Company  sells   printed   circuit
materials  to  these customers pursuant to  purchase  orders
submitted by such customers to the Company.

Definitive Proxy Statement of Schedule 14A

Executive Compensation, page 6

COMMENT:

     2.   As you are aware, the Division has recently released
          Staff observations relating to a focused review of executive
          compensation disclosure.  This guidance, which is available
          on our website at
          http://www.sec.gov/divisions/corpfin/guidance/execco
          mpdisclosure.htm, may be helpful as you draft  future
          versions  of  your executive compensation  and  other
          related  disclosure.   In drafting  future  executive
          compensation   disclosure,   please    consider    in
          particular  providing a more complete description  of
          your executive compensation practices  in the
          following areas:

       *  appropriate analysis and insight into how the Committee
          determined specific payouts;
	 *  benchmarking of the elements of your compensation
 	    program; and
	 *  appropriate disclosure of the specific items of
	    corporate performance that are taken into consideration in
          making compensation decisions and how specific forms of
	    compensation are structured and implemented to reflect these
	    performance items.

RESPONSE:

The Company  will review  its  executive compensation
disclosure in light of the recent staff guidance relating to
executive compensation disclosure.

Signatures

COMMENT:

     3.   It does not appear that your Form 10-K has been signed
          by either your principal accounting officer or controller,
          as is required by General Instruction D to the Form 10-K.
          If a person acts in more than one of these capacities, the
          signature page must indicate all of the capacities in which
          they are signing.  Please advise.

RESPONSE:

The  Form  10-K was signed by James L. Zerby, the  principal
financial officer at the time, and he was also the principal
accounting  officer.  The Company did not have a controller.
It was an oversight that Mr. Zerby was not identified as the
Company's  principal  accounting officer,  as  well  as  its
principal  financial officer.  The Company's Form  10-K  for
its  fiscal year ending March 2, 2008 will indicate all  the
capacities in which the persons are signing.

General

The  Company  acknowledges 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.

The  information  in the foregoing responses  that  will  be
included  in the Company's Form 10-K Annual Report  for  the
fiscal year ending March 2, 2008 will be in such Report that
will be filed on or before May 16, 2008.

Please provide any questions or comments that the staff  may
have  with respect to our responses to the staff's  comments
to   Stephen  Gilhuley,  Park's  Executive  Vice  President,
Secretary and General Counsel, or Matthew Farabaugh,  Park's
Vice  President and Controller, at 631-465-3600 or send them
via facsimile to 631-465-3100.

Very truly yours,

PARK ELECTROCHEMICAL CORP.

Stephen E. Gilhuley
Executive Vice President, Secretary and General Counsel

jc

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