SecProbe.io

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March 31, 2005

Mail Stop 0306

Morris H. Wheeler, President and Chief Executive Officer
Cohesant Technologies Inc.
5845 West 82nd Street, Suite 102
Indianapolis, Indiana 46278

Via U S Mail and FAX [(317)875-5456]

Re:	Cohesant Technologies Inc.
	Form 10-KSB for the fiscal year ended November 30, 2004
	Form 10-QSB for the fiscal quarter ended February 28, 2005
	File No.  1-13484

Dear Mr. Wheeler:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures, and do not intend to expand our review to
other
portions of your documents. Where indicated, we think you should
revise your documents in response to these comments in all future
filings with the Commission.  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 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.

Mr. Morris H. Wheeler
Cohesant Technologies Inc.
March 31, 2005
Page 2

Form 10-KSB for fiscal year ended November 30, 2004

Financial Statements

Balance Sheet - Page F-3

1. In future filings, please present trade accounts receivable
separately from notes receivable. In addition, notes receivable
from
related parties should also be reported separately from other
notes
receivable.

2. We note the "other" category represents 21% of current
liabilities.  In future filings, please disclose the major
components
included in these amounts.

Notes to the Financial Statements

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

3. We note you sell equipment and other products, but have not
presented your policy for product warranty obligations.  In future
filings, please present your policy, if material.  Also include
the
disclosures for product warranties required by paragraph 14 of FIN
45, if material.

(b)   Revenue Recognition - Page F-8

4. In future filings, please expand to provide more specific
details
of your revenue recognition policy for all significant products
and
services.  This should address whether there are any rights of
return, customer acceptance, installation or other post-shipment
obligations and how this impacts revenue recognition. This policy
should clearly indicate how revenue recognized "at shipment" meets
the criteria for revenue recognition of SAB 104.

5. We read on page 4 that sales of replacement and spare parts
represented 33.7% of GCI sales in 2004, and on page 5 that Raven
also
sells spare parts.  In future filings, please include your
accounting
policy for sales of replacement and space parts. These sales
should
also be further discussed in MD&A. if material.

Mr. Morris H. Wheeler
Cohesant Technologies Inc.
March 31, 2005
Page 3

6. We read on page 7 that most of your sales are to independent
distributors and certified applicators.  Please disclose in future
filings, whether revenue is recognized upon shipment to
distributors
and applicators or upon shipment to their third party customers.
If
revenue is recognized upon shipment to distributors and
applicators,
please address whether there are any rights of return, customer
acceptance, installation or other obligations that could impact
revenue recognition.  In addition, clarify whether the price is
fixed
at the time of shipment, or whether there are any subsequent
credits,
adjustments or sales incentives given to distributors and how this
impacts revenue recognition.

(g)   Inventory - Page F-9

7. In future filings, please disclose the amount of your reserve
for
obsolete and slow-moving inventory.

Note 3  Shareholders` Equity

-- Restricted Stock  - Page F-14

8. In future filings, please disclose the aggregate value assigned
to
the shares granted on June 10, 2004 and October 1, 2004.  In
addition, disclose how this value was determined.

Note 9  Segment Information - Page F-17

9. We see in your press releases that you describe your sales in
terms of two product lines: Equipment and Materials.  In future
filings, please disclose the sales from each of your product
lines.
For guidance, please see paragraph 37 to FAS 131.

10. In future filings, please revise your geographic disclosures
to
report domestic (US) sales separately from sales in Canada and
other
North American countries.  Also, please report sales from Europe
separately from the Middle East.

*  *  *  *  *  *  *

Mr. Morris H. Wheeler
Cohesant Technologies Inc.
March 31, 2005
Page 4

      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 response letter that keys your responses to our
comments and provides the requested supplemental information.
Confirm that you will comply with these comments in all future
filings with the Commission.  Detailed response letters greatly
facilitate our review.  Please file your response letter on EDGAR
under the label "CORRESP."  Please understand that we may have
additional comments after reviewing your responses to our comments
and the requested supplemental information.  When sending
supplemental information regarding this filing, please include the
following ZIP+4 code in our address:  20549-0306.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain 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 the filing;

* 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.

      You may contact Jeanne Bennett at (202) 942-1915 or me at
(202)
942-1791, if you have questions regarding our comments.

      Sincerely,

      							Brian R. Cascio
      							Accounting Branch Chief
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