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								April 15, 2005
Zip+4 Code:  20549-0305

Via Fax & U.S. Mail

Mr. Dominick A. Pagano
President and Chief Executive Officer
EDAC Technologies Corporation
1806 New Britain Avenue
Farmington, CT 06032

RE:	EDAC Technologies Corporation (the "Company")
	Form 10-K for the year ended January 1, 2005
	File No. 0-14275

Dear Mr. Dominick A. Pagano:

Based upon an examination restricted solely to considerations of
the
Financial Statements, Management`s Discussion and Analysis, and
Selected Financial Data, the staff has the following comments on
the
above-referenced document.  We think you should revise all future
filings in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
response.  In some of our comments, we may ask you to provide us
with
supplemental information so 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.

Please respond to confirm that such comments will be complied
with,
or, if certain of the comments are deemed inappropriate by the
Company, advise the staff of the reason thereof.

Pursuant to Rule 101(a)(3) of Regulation S-T, your response should
be
submitted in electronic form, under the label "corresp" with a
copy
to the staff.  Please respond to these comments within fifteen
(15)
business days.

Form 10-K and Annual Report for the year-ended 01/01/2005

Market Information

1. You have disclosed that your company`s ability to pay dividends
is
restricted by certain loan agreements. In future filings, please
revise the notes to the company`s financial statements to disclose
the nature and terms of the dividend restrictions imposed by the
company`s loan agreements. Refer to the requirements of Rule 4-
08(e)
of Regulation S-X.

Selected Financial Information

2. Item 301(b)(2) of Regulation S-K requires you to briefly
describe
or cross-reference to a discussion of factors which materially
affect
the comparability of the information reflected in the "Selected
Financial Information" section of your document.  For example,
your
disclosures should briefly describe the effects that each of your
debt restructurings, as well as the significant changes in the
deferred tax asset valuation allowance, had on the comparability
of
net income over the five year period presented.  Additionally, if
there were significant factors which resulted in the material
decline
in revenues and assets of your company between fiscal year 2001
and
fiscal year 2002, these factors should be discussed.  Please
revise
your disclosures in future filings accordingly.

Management Discussion and Analysis of  Financial Condition and
Results of Operations

Results of Operations

3. One of the primary objectives of your MD&A - Results of
Operations
disclosures should be to provide a narrative explanation of the
financial statements that enables investors to see the company
through the eyes of management.  The MD&A section of your document
should not merely restate what happened in the year; but instead,
it
should analyze the underlying factors affecting the results of
operations - including a focus on the effects of trends, events,
demands, commitments and uncertainties on your operations.  For
example, you should specifically address (1) the reasons behind
the
continued decline in sales to aerospace customers and to the
commercial jet engine industry in general, (2) the effect that the
loss of your long-term purchase agreement with your largest
aerospace
customer has had on aerospace revenues (3) the reasons behind the
significant increase in sales to customers in the machine tool
industry, and (4) whether revenues have been affected by changes
in
sales volume and / or price changes.  Please expand upon the
disclosures contained in the MD&A - Results of Operations section
of
your document accordingly.  This should include other matters that
may require expanded discussion but are not specifically cited
above.
Refer to our most recent Interpretive Release about Management`s
Discussion and Analysis (FR-72) for further guidance.

Liquidity and Capital Resources

4. In conjunction with the refinancing your company`s loan
facilities
with its primary lender on January 3, 2005, your company obtained
a
new revolving line of credit which provides for borrowings up to
$5,000,000.  Please specifically disclose the expiration date of
this
loan facility in your discussion of liquidity and your debt
footnote.

Inventory

5. In this section of your document and Note A (Inventories), you
have discussed a transaction consummated with your largest
aerospace
customer, which resulted in the receipt of a $1.8 million advance
and
a reduction to inventory of $1.0 million in fiscal year 2004, with
the recognition of $785,000 in revenue previously in 2002.  Please
completely and clearly provide us with further information
regarding
this transaction.

6. Although your disclosure indicates that the customer took title
to
the related inventory upon payment of the advance in July 2004, it
is
unclear why you previously recognized approximately $800,000 of
revenue in 2002 when such contracts were put on hold by the
customer.
Please specifically address why revenue was recognized (with the
related reduction of inventories) previously in fiscal 2002 when
title to the inventory did not pass to the customer until July
2004.
Your response should address the applicability of the delivery and
performance requirements in Section 3.a. of Topic 13 in the Staff
Accounting Bulletins (i.e. SAB 104) on recognition of revenue for
the
criteria cited under that type of arrangement where the customer
did
not take title to the inventory previously.

Critical Accounting Policies and Estimates

7. The purpose of the critical accounting estimate disclosures is
to
provide the reader with greater insight into the quality and
variability of estimates that involve significant levels of
subjectivity and judgment, and which have a material impact on the
financial condition and operating performance of the company.  The
required disclosures should supplement, not duplicate, the
description of accounting policies in the notes to the financial
statements.  For example, your disclosures related to inventory
should be expanded to discuss why the assumptions and / or
estimate
related to your slow moving or obsolescence reserve bears risk of
change, how accurate the assumptions and estimate have been in the
past, how much the assumptions and estimate hav changed in the
past,
and whether the assumptions and estimate are reasonably likely to
change in the future.  Please revise your critical accounting
estimate disclosures accordingly.  Refer to our most recent
Interpretive Release about Management`s Discussion and Analysis
(FR-
72) for further guidance.

8. Your company proclaims on its website that its repair warranty
and
turnaround are amongst the best in the industry.  We also note
that
your revenues are generated through several complex products, some
of
which require significant levels of precision and allow for
minimum
error tolerance, as well as require customer acceptance.  As such,
please tell us and expand the "Critical Accounting Policies and
Estimates" and "Significant Accounting Policies" sections of your
document to disclose how your warranty expense and any sales
returns
are accounted for.  With respect to product warranties, please
provide all appropriate disclosures in accordance with the
requirements of paragraph 14 of FASB Interpretation No. 45.  This
should include the tabular reconciliation of the changes in the
product warranty liability account with appropriate disclosure of
the
reasons for any material changes from period to period.

Quantitative and Qualitative Disclosures About Market Risk

9. Your disclosures regarding your exposure to interest rate risk
do
not appear to comply with the requirements of Item 305(a) of
Regulation S-K.  Please present your quantitative disclosures
about
market risk so that they are presented in one of the suggested
formats outlined in Item 305(a) of Form Regulation S-K.

Consolidated Balance Sheets

10. We note that your company`s accounts receivable balance
increased
from approximately $3.2 million in 2003 to approximately $6.5
million
in 2004, yet no adjustment was made to the allowance for doubtful
accounts balance carried by your company.  Please tell us why you
believe the company`s allowance for doubtful accounts balance
remains
sufficient, despite the significant increase in the company`s
accounts receivable.  Within your response, please provide a
detailed
explanation of the factors considered when calculating your
reserve.
Also, please detail the reason(s) for the significant increase in
accounts receivable from the prior year and consider a discussion
in
the liquidity section of MD&A (i.e. operating cash flows)
pertaining
to this matter.

Notes to Consolidated Financial Statements

Note G - Income Taxes, page 28

11. We note that your company reversed a significant portion of
the
valuation allowance which was carried against its deferred tax
asset
balance.  With a view toward expanded disclosure, please tell us
in
detail what factors you considered and what assumptions you used
to
determine the portion of the deferred tax asset balance that your
company will "more likely than not" recognize.

Note I - Segment Information, page 29

12. In your annual report, you state how diversified the company
is
with revenues generated through the sales of three major product
lines:  Apex Machine Tool, Gros-Ite Spindles, and Gros-Ite
Precision
Aerospace.  Paragraph 37 of SFAS No. 131 requires an enterprise to
report revenues from external customers for each product and
service
or each group of similar products and services.  Please expand
your
disclosures accordingly.

General

13. In each case that we have requested that you expand upon your
disclosures, please include a draft of your proposed expanded
disclosure within your response.

Other

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.

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.

You may contact Jeffrey Sears at (202) 824-5646 if you have
questions
regarding comments on the financial statements and related
matters.
Please contact the undersigned at (202) 942-1952 with any other
questions.

								Sincerely,

								Joe Foti
								Senior Assistant Chief
Accountant

Via facsimile:  Glenn L. Purple, CFO

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Mr. Dominick A. Pagano
EDAC Technologies Corporation
April 15, 2005
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