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INTERMET CORPORATION

5445 Corporate Drive, Suite 200

Troy, MI 48098-2683

Tel: 248-952-2500

Fax: 248-952-2501

November 29, 2005

Mr. Rufus Decker

Accounting Branch Chief

Securities and Exchange Commission

Washington, D.C. 20549-7010

    RE:

    Form 10-K for Fiscal Year Ended December 31, 2004

Forms 10-Q for Quarters Ended March 31 and June 30, 2005

File No. 0-13787

Dear Mr. Decker:

This letter is in response to your comment letter dated September 9, 2005. We appreciate the
additional time granted to us by Mr. Ernest Green to prepare our responses. Your comments are
reproduced below in italics, followed in each case by our response.

In connection with our responses set forth below, INTERMET acknowledges that:

    •

    it is responsible for the adequacy and accuracy of the disclosure in its 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

    •

    it 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 connection with the effectiveness of our amended plan of reorganization and our emergence from
bankruptcy, we filed a Form 15 on November 9, 2005 to terminate the registration of our common
stock under the Securities Exchange Act of 1934. Accordingly, we do not anticipate that we will
make any further filings with the Commission. Nevertheless, in our responses set forth below, we
have, where appropriate, provided additional disclosure to be responsive to your comments.

We respectfully request that we not be required to file an amendment to our fiscal 2004 Form 10-K
as this information has no current value to users of these financial statements due to the
cancellation of our then outstanding common stock upon the effectiveness of our amended plan of
reorganization and subsequent filing of a Form 15 on November 9, 2005 and the application of
fresh-start accounting upon our emergence from bankruptcy on that date.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004

General

    1.

    Where a comment below requests additional disclosures or other revisions, please show us in
your response what the revisions will look like. These revisions should be included in your
future filings, including your interim filings where appropriate.

    Response: As noted above, we filed a Form 15 on November 9, 2005 to terminate the
registration of our common stock under the Securities Exchange Act of 1934. Accordingly, we do
not anticipate that we will make any further filings with the Commission. Nevertheless, we
have, where appropriate, provided additional disclosure to be responsive to your comments.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of Operations, page 21

    2.

    Please discuss the business reasons for the changes between periods in the gross profit and
operating income (loss) of each of your segments discussed in Note 14 of your financial
statements, along with the amounts shown in the corporate and other segment. In circumstances
where more than one factor contributed to a fluctuation in either segment or consolidated
results, you should quantify the incremental impact of each individual factor if practicable.
Please show us what your revised MD&A for 2004 as compared to 2003 will look like. Please
refer to Item 303(a)(3) of Regulation S-K and Financial Reporting Codification 501.04 and
501.06.

    Response: In preparing the response to this comment, we noted that the operating loss
for the Corporate and Other segment in Note 14 included the goodwill and asset impairment
related to the Decatur Foundry. As properly disclosed in MD&A and in Note 6, the goodwill and
asset impairment related to the Decatur Foundry should be included in the Ferrous Metals group.
The revised disclosure of 2004 operating loss for the Ferrous Metals and Corporate and Other
segments is as follows:

    2004 Operating loss

    From

    To

    (in thousands of dollars)

     Ferrous Metals

    (16,906
    )

    (87,508
    )

     Corporate and Other

    (98,413
    )

    (27,811
    )

    The consolidated operating loss of $240.0 million does not change. The following is the
additional MD&A disclosure related to gross profit and operating loss:

    “Our gross profit for 2004 of $16.2 million was 1.9% of sales compared with gross profit for
2003 of $63.8 million, representing 8.7% of sales. The ferrous group gross profit of $15.7
million was 2.80% of sales compared with gross profit for 2003 of $45.7 million representing
9.3% of sales. The decrease in gross profit was primarily due to increased costs of raw
materials, especially scrap steel.

- 2 -

    The light metals group gross profit of $0.7 million was .3% of sales compared with 2003 gross
profit of $17.8 million, representing 7.5% of sales. The decrease in gross margin was due to
increased pricing pressure from our customers, start-up costs associated with product launches
and cost savings programs and new technology implementation.”

    “Operating loss for 2004 was $240.0 million compared to the operating loss of $36.6 million in
2003. The ferrous group operating profit declined $100.9 million from an operating profit of
$13.3 million in 2003 to an operating loss of $87.6 million in 2004. The decrease in operating
profit was primarily due to the 2004 pre-tax goodwill impairment charge of $59.7 million, 2004
pre-tax restructuring and impairment charges of $18.6 million (an increase of $9.5 million
compared to the 2003 charge of $9.1 million) and the decrease in gross profit of $30.0 million
as previously discussed.

    The light metals group operating loss increased $80.4 million, from $44.2 million in 2003 to
$124.6 million in 2004. The increase in operating loss was due to the 2004 pre-tax goodwill
impairment charge of $106.2 million (an increase of $55.1 million compared to the 2003 charge
of $51.1 million), 2004 pre-tax restructuring and impairment charges of $11.3 million (an
increase of $10.7 million compared to the 2003 charge of $0.6 million) and the decrease in
gross profit of $17.1 million as previously discussed.

    The corporate and other group operating loss increased $22.1 million, from $5.7 million in 2003
to $27.8 million in 2004. The increase in operating loss was due to 2004 reorganization charges
of $14.7 million, 2004 pre-tax restructuring and impairment charges of $2.3 million (an
increase of $2.0 million compared to the 2003 charge of $0.3 million), an increase in benefit
reserves of $2.1 million and $1.4 million related to the key employee retention plan.”

    We respectfully request that we not be required to file an amendment to our fiscal 2004 Form
10-K as this information has no current value to users of these financial statements due to the
cancellation of our then outstanding common stock upon the effectiveness of our amended plan of
reorganization and subsequent filing of a Form 15 on November 9, 2005 and the application of
fresh-start accounting upon our emergence from bankruptcy on that date. We will correct our
MD&A prospectively if we are ever required to disclose this information.

Tabular Disclosure of Contractual Obligations, page 27

    3.

    Please revise your table of contractual cash obligations to include estimated interest
payments on your debt. Because the table is aimed at increasing transparency of cash flow, we
believe these payments should be included in the table. Please also disclose any assumptions
you made to derive these amounts. At a minimum interest payments should be disclosed in a note
to the table. Please refer to note 46 of SEC Release 33-8350.

    Response: At the time our 10-K was filed, the status of our bankruptcy filing made
estimating future interest payments impossible and not meaningful. The following is our
additional disclosure:

- 3 -

    “Estimated interest on our long-term term loan not subject to compromise will be approximately
$8.0 million in 2005 up to the anticipated emergence from Chapter 11 in November 2005. At
emergence, the majority of the existing debt will be eliminated. Borrowings under the revolver
and our short-term lines of credit are based on working capital requirements and bear interest
at variable rates.”

Financial Statements, page 31

Consolidated Statements of Operations, page 31

    4.

    To the extent interest expense differs from stated contractual interest, please disclose this
parenthetically on the face of the statement of operations. Please refer to paragraph 29 of
SOP 90-7.

    Response: Although this information was not disclosed parenthetically on the face of
the statement of operations, the following information was disclosed in Note 8, Debt:

    “We paid interest of $21.5 million, $28.9 million and $26.5 million in 2004, 2003 and 2002,
respectively. No interest expense was capitalized in 2004 or 2003. During our bankruptcy
proceedings, we have not been paying interest on unsecured pre-petition obligations and, as of
the date of filing of the bankruptcy proceedings, we ceased accruing interest on all unsecured
pre-petition debt in accordance with SOP 90-7. Interest expense not accrued or recorded on
unsecured pre-petition debt totaled $4.3 million at December 31, 2004.”

Consolidated Statements of Cash Flows, page 34

    5.

    Please confirm that cash flows from all reorganization items have been separately presented
in accordance with paragraph 31 of SOP 90-7 or revise your presentation accordingly.

    Response: Reorganization items were not presented separately in the statement of cash
flows. The following is our additional disclosure which presents cash flows from reorganization
items separately and changes our 2004 cash flow statement column:

    From

    To

    (in thousands of dollars)

    Amortization of debt discount and issuance costs

    8,389

    4,406

    Reorganization charges

    —

    14,733

    Changes in accounts payable and current liabilities

    29,032

    18,282

Note 1 — Description of Business and Summary of Significant Accounting Policies, page 36

    6.

    Please disclose the types of expenses that you include in the cost of sales line item and the
types of expenses that you include in the selling, general and administrative line item.
Please tell us whether you include inbound freight charges, purchasing and receiving costs,
inspection costs, warehousing costs, internal transfer costs, and the other costs of your
distribution network in the cost of sales line item. With the exception of warehousing costs,
if you currently exclude a portion of these costs from cost of sales, please disclose:

- 4 -

    •

    in a footnote the line items that these excluded costs are included in and the amounts
included in each line item for each period presented, and

    •

    in MD&A that your gross margins may not be comparable to those of other entities, since
some entities include all of the costs related to their distribution network in cost of
sales and others like you exclude a portion of them from gross profit, including them
instead in a line item such as selling, general and administrative.

Response: Cost of Goods Sold includes the cost of all raw material, as well as
internal and external costs associated with the production and shipment of our products.
Inbound freight charges, purchasing and receiving costs, inspection costs, warehousing costs,
internal transfer costs, and the other costs of our distribution network are included in the
Cost of Good Sold line item. Selling, General and Administrative Expense includes all costs
associated with the sales and marketing of our products and the administrative expenses
associated with the commercial aspects of the business. The following is our additional
disclosure:

“Cost of Goods Sold includes all raw material, as well as internal and external costs
associated with the production and shipment of our products. Selling, general and
administrative expense includes all costs associated with the sales and marketing of our
products and the administrative expenses associated with the commercial aspects of the
business.”

Business, page 36

    7.

    You indicate that you perform value-added services in addition to producing castings. Please
tell us and disclose the amount of service revenues and related cost of sales as required by
Rule 5-03(b)(1) and (2) of Regulation S-X on the face of the income statement, if applicable.

    Response: We do not have service revenues as defined by Rule 5-03(b)(1) and (2) of
Regulation S-X. Our value-added services are included in our casting business and therefore are
not stand-alone revenue generating activities and are not billed separately. The following is
our additional business description disclosure:

    “INTERMET Corporation produces castings in North America and Europe for light and heavy
vehicles, including powertrain, chassis, brake, and body/interior components, as well as
industrial products. In connection with producing castings, we provide our customers with a
range of capabilities including advanced design and engineering, prototype casting, machining
and sub-assembly, which are not billed separately.”

Revenue Recognition, page 37

    8.

    Please expand your revenue recognition policy to disclose the additional factors affecting
recognition discussed under critical accounting policies on page 18.

    Response: The following is our additional disclosure:

- 5 -

“We recognize revenue when persuasive evidence of a final agreement exists, delivery has
occurred, title has transferred, the selling price is fixed or determinable and collectibility
is reasonably assured, which is upon shipment of product. We record provisions against our
gross revenue for estimated product returns and allowances in the period when the related
revenue is recorded. These estimates are primarily based on factors such as historical sales
returns, credit memo activities and changes in our customers’ demand. Should our actual product
returns and allowances exceed our estimates, additional provisions against our revenue would
result.”

Property, Plant & Equipment, page 39

    9.

    The range of useful lives for your machinery and equipment of 2 to 21 years is very broad.
Please separately discuss and disclose the types of assets that fall in each part of the
range.

    Response: The following are the separate sub-categories of assets that fall in each
part of the range of useful lives for our machinery and equipment:

Foundry equipment – 7 to 21 years

Office equipment, furniture and fixtures – 5 to 7 years

Forklifts, trucks and autos – 3 to 5 years

Computers and data processing – 3 to 5 years

Note 3 — Acquisitions page 46

    10.

    You indicate that Melfina — Estudos, Servicos e Participacoes, S.A. had a put option,
requiring you to buy the remaining 25% ownership interest for an additional investment of Euro
4.9 million. Please tell us the terms of the put option and how you accounted for this put
option. Cite the accounting literature used to determine the appropriate accounting. Please
also tell us the offsetting entry in initially recognizing the liability for the put option in
accounts payable.

    Response: On June 25, 2003, we entered into an agreement with Melfina — Estudos,
Servicos e Participacoes, S.A. to acquire 100% ownership of the shares of Fundicao Nodular,
S.A. (“Porto Foundry”), which is located in Porto, Portugal. Previously we owned a 50% interest
in the Porto Foundry. Under the terms of the agreement, we acquired an additional 25% of the
Porto Foundry’s shares for a cash investment of Euro 4.9 million (approximately $5.6 million)
on July 1, 2003, increasing our ownership from 50% to 75%. We had a call option to acquire, and
Melfina — Estudos, Servicos