SecProbe.io

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Mail Stop 0510

            August 8, 2005

Mr. Tiberio Dall`Olio
Chief Executive Officer
Madeco S.A.
Ureta Cox 930
Santiago, Chile

	RE:	Form 20-F for Fiscal Year Ended December 31, 2004
		File No. 1-11870

Dear Mr. Dall`Olio:

		We have reviewed your filing 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 20-F for the Year Ended December 31, 2004

General
1. Where a comment below requests additional disclosures or other
revisions please show us in your response what the revisions will
look like.  Such revisions may be included in your future filings.

Item 3.A. - Key Information - Selected Financial Data
2. Please revise your table to include the U.S. GAAP earnings per
share information as well as any other items required to be
presented
in selected financial data under Chilean GAAP if different on a
U.S.
GAAP basis.  See the minutes to the AICPA International Practices
Task Force July 15, 2003 meeting, specifically Agenda Item 12.

Liquidity and Capital Resources

Contractual Obligations and Commercial Commitments
3. Please revise your table of contractual cash obligations to
clarify whether you have included estimated interest payments on
your
debt.  Because the table is aimed at increasing transparency of
cash
flow, we believe these interest payments should be included in the
table.  Please also disclose any assumptions you made to derive
estimated interest payments.   If you chose to provide a textual
discussion, the discussion should quantify the interest payments
using the same time frames as the table.  Refer to footnote 46 to
Release 33-8350.

Critical Accounting Policies
4. Your reference to your significant accounting policies in your
historical financial statements does not provide the level of
detail
required by SEC Interpretive Release No. 33-8350, SEC Other
Release
No. 33-8040 and SEC Proposed Release No. 33-8098, all of which you
can find on our website at www.sec.gov.  Your critical accounting
policies and estimates section should focus on those estimates
that
are critical to your consolidated financial statements.  The
discussion should include a discussion of the material assumptions
you made in arriving at the critical estimate and advise an
investor
of the financial statement impact if actual results differ from
the
estimate made by management.  Please identify all of your critical
policies and estimates and expand your discussion to address the
following areas:

* Types of assumptions underlying the most significant and
subjective
estimates;

* Sensitivity of those estimates to deviations of actual results
from
management`s assumptions; and

* Circumstances that have resulted in revised assumptions in the
past.

Item 15.
5. You indicate that your chief executive officer and chief
financial
officer concluded that your disclosure controls and procedures
were
effective in timely alerting them to material information required
to
be included in your SEC reports.  Please revise your disclosure to
state your conclusion while providing the complete definition of
disclosure controls and procedures, or alternatively, simply state
that your disclosure controls and procedures are effective, or not
effective, without providing any part of the definition of
disclosure
controls and procedures that is included in Exchange Act Rules
13a-
15(e) and 15d-15(e).  Please note that disclosure controls and
procedures are no longer defined in Exchange Act Rules 13a-14(c)
and
15d-14(c).
6. Please also note that Item 15(d) of Form 20-F requires
disclosure
of any change in your internal control over financial reporting
that
occurred during the period covered by the annual report, rather
than
subsequent to the date of the evaluation.

Financial Statements

Note 2 - Summary of Significant Accounting Policies

h. Property, Plant and Equipment
7. We note the information you presented in the property, plant
and
equipment section of your Business section indicates that certain
of
your production facilities are significantly underutilized.
Clarify
in this note or Note 32 - Differences Between Chilean and United
States Generally Accepted Accounting Principles whether this
underutilization would be a triggering event under SFAS 144, which
would require you to assess these long-lived assets for
impairment.

j. Securities Purchased under Agreement to Resell
8. Please revise your disclosure to clarify the meaning of
"collocation value."

r. Revenue Recognition
9. You state in the Business section that you sometimes customize
products for your customers.  Tell us how your revenue recognition
policy as it relates to the sale of customized products is in
accordance with SAB Topic 13:A for U.S. GAAP purposes.
Specifically
address whether there are customer acceptance provisions with
regard
to these sales.

Note 8 (b) - Inventories - Changes in the Allowance for
Obsolescence
10. We note that you have credited ThCh$446,136 and ThCh$831,471
to
expense related to your inventory allowance for obsolescence.
Under
U.S. GAAP, a reduction in the carrying amount of an inventory item
from cost to net realizable value is viewed as creating a new
"cost
basis" for the item.  As a result, the write-down can be recovered
only through sale or disposition of the item and cannot be
restored
should the market value recover prior to sale or disposition.  See
footnote 2 to paragraph 4 of Chapter 4 of ARB 43.   Please address
this apparent U.S. GAAP difference in Note 32 - Differences
Between
Chilean and United States Generally Accepted Accounting
Principles.

Note 15 - Accrued and Other Liabilities
11. In endnote 1 to this note you refer to Note 2(o) in reference
to
your provision for pending lawsuits and unpaid settlements with
employees.  Note 2(o) does not appear to address these lawsuits.
We
note your statement in Note 22 that you consider it unlikely that
pending lawsuits will significantly affect your results of
operations, financial position or cash flows.  Please tell us more
regarding the nature of these suits, including whether you believe
that additional losses, beyond those already accrued, are
reasonably
possible.  If so, please revise your discussion in this note or
Note
32 - Differences Between Chilean and United States Generally
Accepted
Accounting Principles to include the disclosures required by
paragraph 10 of SFAS 5 and SAB Topic 5:Y.

Note 32 - Differences Between Chilean and United States Generally
Accepted Accounting Principles

1. Differences in Measurement Methods

e. Employee Severance Indemnities
12. Clarify the nature of the shutdown method for accruing
employee
severance costs.

m. Stock Option Plan
13. Clarify where your net loss attributable to common
shareholders,
as reported, and your net loss per share, as reported, information
is
derived.  In this regard, these amounts do not appear to agree to
your historical financial statements.

p. Summary of Income Statement and Shareholders` Equity
Differences
14. We note you have adjusted for the reversal of the asset
revaluation, discussed in section 1(b) of this note, and the
related
accumulated depreciation in a single reconciling line item.
Please
note that such adjustments should be presented on a gross basis
with
separate disclosure of the amounts of accumulated depreciation.

Exhibit 99 - Certifications
15. Please revise your certification to be in the exact form
specified in the instructions to Form 20-F.  In this regard,
please
note that paragraph 6 is no longer required.

*    *    *    *

		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.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 the 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 Scott Watkinson, Staff Accountant, at (202) 551-3741 or,
in
his absence, Jeanne Baker, Assistant Chief Accountant, at (202)
551-
3691.

								Sincerely,

								Rufus Decker
								Accounting Branch Chief

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Mr. Tiberio Dall'Olio
Madeco S.A.
August 8, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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