SecProbe.io

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      March 1, 2005

Mail Stop 0510

By U.S. mail and facsimile to (518) 786-8216

Mr. Glenn H. Epstein
Chairman and Chief Executive Officer
Intermagnetics General Corporation
450 Old Niskayuna Road
Latham, NY  12110

	RE:	Form 10-K for the fiscal year ended May 30, 2004
			File No. 1-11344

Dear Mr. Epstein:

		We have reviewed your response letter dated November 19,
2004 to our letter dated November 5, 2004 and have the following
comment.

Note A - Significant Accounting Policies - Revenue Recognition

1. We note your response to prior comment number one.  We do not
understand why you will "...no longer make any distinction between
revenues accounted for in accordance with SOP 81-1."  Please
provide
us with your revised revenue recognition policy that you will
disclose in future filings.  Ensure your discussion of product
sales
clarifies that title and risk of loss transfer at shipment.

*    *    *    *

		Please respond to this comment 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 response to our
comment 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
response to our comment.

      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 their filings;

* 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) 824-5525 or,
in
his absence, to Jeanne Baker, Assistant Chief Accountant at (202)
942-1835, or the undersigned at (202) 942-1798.

							Sincerely,

							John Hartz
							Senior Assistant Chief
Accountant

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Mr. Glenn H. Epstein
Intermagnetics General Corporation
March 1, 2005
Page 2 of 2

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

         DIVISION OF
CORPORATION FINANCE

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