SecProbe.io

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[Graphic Omitted] IGC  Intermagnetics
                       -------------------
                       General Corporation

                                 March 15, 2005

Mr. John Hartz
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
Washington, DC  20549-0510

Dear Mr. Hartz,

The following is in response to the comment in your letter to Intermagnetics
General Corporation dated March 1, 2005.

                    FORM 10-K FOR THE YEAR ENDED MAY 30, 2004
                    ------------------------------------------

Note A-Significant accounting Policies - Revenue Recognition
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     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.

                  o  RESPONSE;
                  IN FUTURE FILINGS, WE WILL CLARIFY OUR REVENUE RECOGNITION
                  POLICY ON LONG-TERM DEVELOPMENT CONTRACT REVENUE AS ACCOUNTED
                  FOR IN ACCORDANCE WITH SOP 81-1 AND REVENUE RECOGNIZED ON
                  PRODUCT SALES WHEN TITLE AND RISK OF LOSS TRANSFERS AT
                  SHIPMENT AS FOLLOWS:

                           The Company recognizes revenue and profit on
                  long-term development contracts based upon actual costs
                  incurred plus earned profit using the percentage-of-completion
                  method in accordance with Statement of Position ("SOP") No.
                  81-1. These types of contracts typically provide engineering
                  services to achieve a specific scientific result relating to
                  superconductivity. Some of these contracts require the Company
                  to contribute to the development effort. The customers for
                  these contracts are both commercial customers and various
                  state and federal government agencies. When government
                  agencies are providing revenue we do not expect the government
                  to be a significant end user of the resulting products.
                  Therefore, the Company does not reduce Internal Research and
                  Development by the funding received. When it appears probable
                  that estimated costs will exceed available funding, and the
                  Company is not successful in securing additional funding, the
                  Company records the estimated loss on the contract.

                           The Company recognizes revenue in accordance with
                  Staff Accounting Bulletin No. 101 as amended by Staff
                  Accounting Bulletin No. 104, on product that is complete and
                  ready to ship. In these cases, all the criteria for revenue
                  recognition have been met including, but not limited to:
                  persuasive evidence of an arrangement exists; the arrangement
                  includes a product price that is fixed and determinable; the
                  company has accomplished what it must do to satisfy the terms
                  of the arrangement including passing title and risk of loss to
                  our customer upon shipment; and collection from our customer
                  is reasonably assured in accordance with the terms in the
                  arrangement.
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                           In other instances, the Company recognizes revenue in
                  accordance with Staff Accounting Bulletin No. 101 as amended
                  by Staff Accounting Bulletin No. 104, on product that is
                  complete and ready to ship for which our customer has
                  requested a delay in delivery. In these cases, all the
                  criteria for revenue recognition have been met including, but
                  not limited to: the customer has a substantial business
                  purpose, there is a fixed delivery date, title and risk of
                  loss has transferred to our customer, the product is complete
                  and ready for shipment, and the product has been segregated
                  and is not available to be used to fill other orders. Upon
                  notification from our customer the product is shipped to the
                  stated destination.

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     WE ACKNOWLEDGE:

     o   THE COMPANY IS RESPONSIBLE FOR THE ADEQUACY AND ACCURACY OF THE
         DISCLOSURE IN THEIR FILINGS;

     o   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

     o   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.

     ____________________________
     GLENN H. EPSTEIN
     CHAIRMAN AND CHIEF EXECUTIVE OFFICER
     MARCH 15, 2005

     ____________________________
     MICHAEL K. BURKE
     CHIEF FINANCIAL OFFICER AND EXECUTIVE VICE PRESIDENT
     MARCH 15, 2005

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