SecProbe.io

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Mail Stop 0407
      						April 21, 2005

Via U.S. Mail and Fax (507) 625-9191

Mr. David A. Christensen, Chief Financial Officer
Hickory Tech Corporation
221 East Hickory Street,
P.O. Box 3248
Mankato, MN 56002

	RE:	Hickory Tech Corporation
      Form 10-K for the fiscal year ended December 31, 2004
		File No. 0-13721

Dear Mr. Christensen:

      We have reviewed the above referenced filing and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.  Please address the following
comments in future filings.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a future
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so that we may better understand
your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Hickory Tech Corporation
April 21, 2005
Page 2

Form 10-K for the year ended December 31, 2004
Item 9A. Control and procedures, page 52

Control and procedures

1. We note your disclosure that "the Company`s management,
including
the respective persons acting as chief executive officer and chief
financial officer, concluded that the Company`s disclosure
controls
and procedures were effective in timely alerting them to material
information relating to the Company (or its consolidated
subsidiaries) required to be included in the reports it files or
submits under the Exchange Act".  Please confirm in your response
letter, if true, that the Company`s management, including the
respective persons acting as chief executive officer and chief
financial officer, concluded that your disclosure controls and
procedures are also effective in ensuring that information
required
to be disclosed in the reports that you file or submit under the
Exchange Act is accumulated and communicated to your management,
including your principal executive and principal financial
officers,
to allow timely decisions regarding required disclosure.  See Rule
13a-15(e) of the Securities Exchange Act.  Alternatively, you may
simply state, if true, that your chief executive officer and chief
financial officer concluded that your disclosure controls and
procedures are effective.  Please also revise your future filings
accordingly.

2. We note in last sentence that "There have been no significant
changes in the Company`s internal controls or in other factors
that
could significantly affect internal controls."   Please confirm in
writing whether there was any change in your internal control over
financial reporting identified in connection with an evaluation
thereof that occurred during the period covered by the above
report
that has materially affected, or is reasonably likely to
materially
affect, your internal control over financial reporting.  Please
see
Item 308 (c) of Regulation S-K.  Please also revise your future
filings accordingly.

*    *    *    *

	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.
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.

Hickory Tech Corporation
April 21, 2005
Page 3

	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 the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested supplemental information.  Please file your response
letter
on EDGAR.  You may contact Gopal Dharia, Staff Accountant, at
(202)
942-1973 or Terry French, Accountant Branch Chief, at (202) 942-
1998
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 942-1990 with any
other questions.

							Sincerely,

							Larry Spirgel
							Assistant Director

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