SecProbe.io

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RAYTECH

                                                                 August 31, 2005

Mr. John Hartz
Senior Assistant Chief Accountant
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549

      Re:   Raytech Corporation
            Form 10-Q for the Fiscal Year Ended January 2, 2005
            File No. 1-9298

Dear Mr. Hartz:

The following information is in response to your comment letter dated July 20,
2005 pertaining to Raytech Corporation. Our responses are organized in the same
order and format as your inquiries.

Consolidated Statements of Operations

We have reviewed your response to our prior comments four and five and
appreciate the additional information. Clarify that in future filings you will
reclassify prior periods as appropriate and consistent with your response.

      We agree that in future filings we will reclassify prior periods as
      appropriate and be consistent with our previous response to this issue.

Revenue Recognition

We note your enhanced disclosures included in your most recent Form 10-Q. In
future filings, include the statement, if true, that this policy is followed
consistently for all periods presented regarding any and all losses on contracts
where costs exceed selling price. Specifically, losses are consistently recorded
based on:

-     All inventory and firm purchase orders only;
-     The difference between contracted selling price and fully absorbed
      inventory costs (consistent with our normal GAAP inventory historical cost
      system).

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Mr. John Hartz
August 31, 2005
Page 2

      We have expanded the revenue recognition disclosure in the Form 10-Q for
      the period ended July 3, 2005 to include the additional disclosures
      suggested above and will continue this disclosure in future filings.

Note 9 - Litigation

We have reviewed your response to our prior comment ten and appreciate the
additional information. If it is reasonably possible that additional losses
related to the RPC facility, or to Ferndale, could be material, revised future
filings to so state, and if you can, provide an estimate of the range of
additional loss, or state that such an estimate cannot be made.

Revise your litigation footnote to clarify that you do not accrue probable and
estimable litigation costs in the estimated accruals. If litigation costs are
material to any particular period, or to an understanding of any particular
contingency, disclose the periodic expense amounts.

      We have reviewed the estimates of costs in our disclosure and feel, at
      this time, that the disclosures reflect management's best estimate and
      that no additional material costs are likely. We will consistently address
      these estimates in future filings based on current information at the time
      of the filing.

      We have revised the footnote to reflect the method of recording legal
      expenses.

Note 11 - Income Taxes

In future filings:

-  Disclose the particular years in which significant amounts of NOL
   carryforwards, related to those NOLs that may inure to the PI Trust, will
   expire;
-  Provide a detailed discussion in MD&A concerning significant increases or
   decreases in your valuation account. Discuss the underlying changes in
   events, tax planning and expectations for future taxable income that changed
   from the previous period. Be specific and quantify your reasoning;
-  Make sure that your MD&A is consistent with your expectation that you will
   not have taxable income related to the Domestic Wet Friction business. For
   example, the last paragraphs on pages 15 and 16 should be balanced with the
   expectations that it is more likely than not that most of the deferred tax
   assets will not be realized.
-  Discuss in better detail the uncertainties surrounding the method of
   allocation of the current and future operating losses between you and the PI
   Trust. What alternative methods could result? What impact would an alternate
   method have on your financial condition and results of operation?

      We have disclosed in the Income Taxes footnote the expiration dates of the
      NOL carryforwards that inure to the benefit of the PI Trust. In both the
      footnote and in the MD&A we have provided a detailed discussion of the
      changes in the valuation account. There have been no changes in the tax
      planning or expectations for future income that changed from the previous
      period. The disclosures in the MD&A relating to the performance of the
      Domestic OEM segment provide the reader with caution as to the current and
      future profitability of this segment.

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Mr. John Hartz
August 31, 2005
Page 3

      We have provided the reader with an understanding of alternative methods
      of allocating the current and future operating losses between the PI Trust
      and the Company. The impact of such alternatives has also been disclosed.
      These disclosures are contained in the Income Taxes footnote.

If I can be of further assistance, please do not hesitate to contact me.

                                                Sincerely,

                                                /s/ John B. Devlin

                                                John B. Devlin
                                                Vice President, Treasurer and
                                                Chief Financial Officer

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