SecProbe.io

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Mail Stop 03-06

May 13, 2005

Via U.S. Mail and Facsimile (614-486-0912)

Gerald S. Blaskie
Chief Financial Officer
Superconductive Components, Inc.
2839 Charter Street
Columbus, Ohio 43228

	Re:	Superconductive Components, Inc.
		Form 10-KSB for year ended December 31, 2004
		Filed March 31, 2005
		File No. 000-31641

Dear Mr. Blaskie:

      We have reviewed your filings and have the following
comments.
We have limited our review to matters related to the issues raised
in
our comments.  Where indicated, we think you should revise your
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 explanation.  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 comment or on any other
aspects
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-KSB for the year ended December 31, 2004

Item 1 - Financial Statements

Note 2. Summary of Significant Accounting Policies - Page F- 8

Revenue Recognition - Page F-11

1. We note that you record provisions for `other adjustments.`
Tell
us and revise future filings to discuss the nature of these other
adjustments.
2. You state that revenue from contract research provided for
third
parties is recognized when the contracted work has been performed
or
as milestone results have been achieved.  Based on this
disclosure,
it is not clear whether you utilize the percentage of completion
method or the completed contract method.  Please tell us and
revise
future filings to disclose the specific methods used to recognize
revenue on these contracts.  If you use the percentage of
completion
method, tell us and revise future filings to disclose what factors
you consider in measuring your progress towards completion.  If
you
use the completed contract method, tell us why you believe this
method is appropriate based on the guidance in paragraphs .31-.33
of
SOP 81-1.
3. We note that you incurred a negative margin on your contract
research services in 2004.  It appears that certain of your
research
contracts may be loss contracts.  Tell us and revise future
filings
to disclose your accounting policy for loss contracts.  Refer to
paragraphs .85-.89 of SOP 81-1.

* * * * * * * *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your amendment and
responses to our comments.

	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 Praveen Kartholy, Staff Accountant, at (202)
824-5465, or Kevin Vaughn, Reviewing Accountant, at (202) 824-
5387,
or me at (202) 942-7903 if you have questions regarding these
comments.

					Sincerely,

					Michele Gohlke
					Branch Chief

Mr. Gerald S. Blaskie
Superconductive Components, Inc.
May 13, 2005
Page 3

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