SecProbe.io

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[SCI ENGINEERED MATERIALS LOGO]

              AN OPERATING UNIT OF SUPERCONDUCTIVE COMPONENTS, INC.
              2839 Charter St., Columbus, Ohio 43228
              Phone: (614) 486-0261, 1-800-346-6567 Fax: (614) 486-0912
              www.SCIEngineeredMaterials.com

May 24, 2005

Ms. Michele Gohlke
Branch Chief
United States Securities and Exchange Commission
Washington, D.C.  20549

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

Dear Ms. Gohlke:

We have received the comments to the Form 10-KSB filed by Superconductive
Components, Inc. (the "Company") for the year ended December 31, 2004, as set
forth in your letter dated May 13, 2005.

Your questions relate to Item 1 - Financial Statements. Note 2 refers to the
Summary of Significant Accounting Policies and your questions are specific to
Revenue Recognition on page F-11. Our responses to your comments in this letter
are numbered to correspond to the numbers contained in your May 13, 2005 letter.

     1.  In response to your comment, we have reviewed adjustments to revenue
         for the three year period ended December 31, 2004 and have determined
         that the only provisions recognized for product sales pertain to
         discounts and returns. For all future filings, we will remove the
         reference to other adjustments since we have determined that there are
         no other adjustments other than discounts or returns.

     2.  In response to your comment, most of our contracts are fixed fee
         research contracts. We submit a proposal that includes the total number
         of hours, which is used to compute direct labor costs and related
         payroll costs, direct costs associated with the contract, and our
         actual overhead rate using the direct labor hours. We are then awarded
         a contract for the sum of our total costs with no gross margin. These
         contracts range from six months to three years and include milestones
         and monthly, quarterly or other reporting criteria within the contract
         period with a final report due at the end of the contract. We
         continually monitor our progress on these contracts as to hours
         incurred, estimated hours to complete, costs incurred with estimates to
         complete and a comparison of milestones achieved based on our
         anticipated timeline. Using these guidelines, we use the

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[SCI ENGINEERED MATERIALS LOGO]

              AN OPERATING UNIT OF SUPERCONDUCTIVE COMPONENTS, INC.
              2839 Charter St., Columbus, Ohio 43228
              Phone: (614) 486-0261, 1-800-346-6567 Fax: (614) 486-0912
              www.SCIEngineeredMaterials.com

         percentage of completion method to account for these contracts. We will
         revise future filings to identify that we utilize the percentage of
         completion method and identify factors used in assessing our progress
         on these contracts.

     3.  In response to your comment, some of the research contracts provided to
         third parties relate to contracts for products that are manufactured by
         the Company in our capacity as a subcontractor. A third party research
         contract in 2004 included estimated quantities that were to be required
         over the contract period for our total amount of estimated revenues and
         costs. However, we were only required to manufacture and ship product
         inventory based on specific requests by the contractor. In accordance
         with the provisions of the contract, we billed 50% of our total costs
         on a monthly basis for work performed in connection with this contract.
         As a result, the Company disclosed negative margin in connection with
         this research contract. During 2004, one of the other parties to this
         contract terminated the contract. The Company recorded all related
         revenue and expenses in connection with the contract at the time of the
         contract termination notification. We will revise future filings to
         identify our accounting policy for loss contracts.

The Company acknowledges the following:

         -        The Company is responsible for the adequacy 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.

If you have any questions feel free to contact me at 614/486-0261.

Sincerely,

/s/ Gerald S. Blaskie
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Gerald S. Blaskie
Chief Financial Officer
Superconductive Components, Inc.

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