SecProbe.io

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Mail Stop 7010

      July 18, 2005

Mr. Vernon E. Bachman
Vice President, Secretary-Treasurer and Principal Accounting
Officer
Vulcan International Corporation
300 Delaware Avenue, Suite 1704
Wilmington, Delaware, 19801

	RE: 	Form 10-K for the Fiscal Year ended December 31, 2004
                    	Form 10-Q for the Fiscal Quarter ended
March
31, 2005
                    	File No. 1-10219

Dear Mr. Bachman:

		We have reviewed these filings and have the following
comments.  If you disagree with a comment, 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
information so we may better understand your disclosure.  After
reviewing this information, we may 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.

Form 10-K for the Year Ended December 31, 2004

General
1. Where a comment below requests additional disclosures or other
revisions, please show us in your supplemental response what the
revisions will look like.  With the exception of the comments
below
that specifically request an amendment, all other revisions may be
included in your future filings, including your interim filings
where
applicable.

Business, page 1
2. Please disclose the name of any customer that represents more
than
10% of consolidated revenues in accordance with Item 101(c) of
Regulation S-K.

Financial Statements and Supplementary Data, page 7
3. Please disclose the reasons for the decrease in gross profit
and
income (loss) from continuing operations during the fourth quarter
of
2004, including any unusual adjustments or transactions.    Please
also explain the reasons for the decrease in gross profit during
the
third quarter of 2004 and the first quarter of 2003 and the large
increase in income (loss) from continuing operations during the
third
quarter of 2003, including any unusual adjustments or
transactions.
Item 302(a)(3) of Regulation S-K requires the disclosure of
adjustments that are material to the results of a quarter.
Paragraph
31 of APB 28 also requires the disclosure of significant
adjustments
and unusual or infrequently occurring items recognized during the
fourth quarter.

Management Analysis of Recent Years, page 16
4. Please enhance your management analysis disclosures as follows:
* Quantify your explanations for significant changes in rubber,
foam
and timber product sales and cost of sales in terms of increases
or
decreases in prices and volume and include an explanation of the
underlying reasons for the changes,
* Discuss significant changes in commercial real estate revenues,
* Discuss the reasons for the sales decrease in foreign countries
to
$23,991 in 2004 from $390,690 in 2003.  Also discuss the reasons
for
the sales increase in foreign countries to $390,690 in 2003 from
$203,345 in 2002, and
* Quantify the increases or decreases in cost of sales, operating
expense, and general and administrative expenses for each segment,
together with an explanation of the underlying reasons.
Management`s discussion and analysis should allow the investor to
see
the company through the eyes of management.  Please revise the
discussion with this underlying thought in mind.  Please Refer to
Item 303 of Regulation S-K.
5. Please disclose your critical accounting policies.
Additionally,
for each critical accounting policy or estimate, please discuss
the
likelihood of materially different reported results if different
assumptions or conditions were to prevail.  To the extent
practicable
and meaningful, you should also quantify the effect changes in
assumptions and estimates would have on your overall financial
performance.  See SEC Releases 33-8040 and 33-8098.

Financial Statements

Consolidated Statements of Income, page 22
6. Please tell us why you do not present your statements of income
in
accordance with Rule 5-03 of Regulation S-X for each of the
following
items:
* Timber sales are a recurring source of tangible product sales.
These sales and their related cost of sales should be presented
within net sales and cost of sales according to Rule 5-03(b)(1)(a)
and (2)(a) of Regulation S-X,
* Income from commercial real estate rentals and the related costs
should be presented as separate components if revenues represents
more than 10% of net sales according to Rule 5-03 (b)(1)(c) and
(2)(c) of Regulation S-X.  Given your recent purchase of a third
commercial property in Cincinnati, Ohio you appear to be at or
approaching the 10% threshold,
* Dividends and interest income should be presented outside of
revenue, according to Rule 5-03 (b)(7) of Regulation S-X,
* Material amounts within net gains on the sale of property,
equipment, and securities should be separately stated in the
statement of income or in a note thereto clearly indicating the
nature of the transactions out of which the items arose, according
to
Rule 5-03 (b)(7) of Regulation S-X,
* Minority interest should be presented below the income tax
provision according to Rule 5-03 (b)(12) of Regulation S-X, and
* The income before gain on disposal of assets line item
classification is not in accordance with Regulation S-X.  Please
delete.

Consolidated Statements of Cash Flows, page 24
7. Please tell us the amount of the notes receivable and if the
notes
receivable arise from the sale of goods and services.  If the
notes
receivable arise from the sale of goods and services, please tell
us
your basis for classifying the collection on notes receivable
amounts
in investing activities, in light of paragraph 22 of SFAS 95.

Note 1 - Summary of Significant Accounting Policies, page 25
8. We note your disclosure regarding goodwill.  Please tell us the
amount and classification of your goodwill balance.  Please also
help
us understand why you have not recognized any goodwill impairment,
given that your market value has consistently been less than the
amount of your equity.
9. Please disclose your revenue recognition accounting policy for
rubber, foam and timber product sales.  Please also disclose your
revenue recognition policy for commercial real estate service
revenues.  Your disclosure should clearly describe how your
revenue
recognition policies are in accordance with SAB Topic 13:A.
Please
also disclose your accounting policy for allowances established
for
sales returns as required by SFAS 48.
10. Please provide the credit risks disclosure arising from the
concentration with three customers of 45% and 47% of your net
sales
in 2004 and 2003.  Please refer to paragraph 15A of SFAS 107.

Note 12 - Business Segments, page 39
11. Please provide the enterprise-wide product line and service
disclosures required by paragraph 37 of SFAS 131.
12. Please disclose significant non-cash credits, other than
depreciation and amortization expense, such as the $1,433,152
environmental remediation costs in 2003 and the $130,000 credit
for
real estate tax assessment in 2004 on operating income for each
segment included in operating profit (loss) for each segment in
accordance with paragraph 27 of SFAS 131.
13. Please separately identify and describe the amounts of
significant reconciling items included in general corporate
income.
Please refer to paragraphs 32 of SFAS 131.

Form 10-Q for the Quarter Ended March 31, 2005

Item 4. Controls and Procedures, page 13
14. You disclose that your disclosures controls and procedures are
adequate, rather than effective.  Please confirm to us that your
disclosure controls and procedures are effective as of March 31,
2005.  In future filings, please revise your disclosures to state
that your disclosure controls and procedures are effective.  If
they
are not effective as of March 31, 2005, please amend your Form 10-
Q
to include such disclosure.

*    *    *    *

      		Please respond to these comments within 10 business
days, or tell us when you will provide us with a response.  Please
provide us with a response letter that keys your responses to our
comments and provides any requested information.  Detailed letters
greatly facilitate our review.  Please file your response on EDGAR
as
a correspondence file.  Please understand that we may have
additional
comments after reviewing your 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 required
under
the Securities Exchange Act of 1934 and that they have provided
all
information investors require for an informed decision.  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 their filings;

* staff comments or changes to disclosure in response to staff
comments 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.

       	If you have any questions regarding these comments,
please
direct them to Gus Rodriguez, Staff Accountant, at (202) 551-3752
or,
in his absence, Nilima Shah, the undersigned, at (202) 551-3255.

          						Sincerely,

								Nilima Shah
								Branch Chief
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Vernon E. Bachman
Vulcan International Corporation
July 18, 2005
Page 1 of 6

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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