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Correspondence

    Pfeiffer Vacuum Technology AG

    Berliner Strasse 43, D-35608 Asslar

    Telefon: 0049 (0) 6441/802-0

    Telefax: 0049 (0) 6441/802-365

    www: pfeiffer-vacuum.net

VIA EDGAR

Mr. Rufus Decker, Branch Chief

Mr. Gus Rodriguez, Staff Accountant

Mr. Nudrat Salik, Staff Accountant

Division of Corporation Finance

United States Securities and Exchange Commission

450 Fifth Street, N.W., Stop 4-5

Washington, D.C. 20549

Asslar, June 21, 2005

    Re:

    Pfeiffer Vacuum Technology AG

    Form 20-F for the Fiscal Year Ended December 31, 2004

    File No. 1-14264

Dear Mr. Decker, Mr. Rodriguez and Mr. Salik:

     This letter is in response to the comment letter dated May 25, 2005, from Mr. Decker to Mr.
Manfred Bender, Chief Financial Officer of Pfeiffer Vacuum Technology AG, a stock corporation
domiciled in Germany (the “Company”), regarding the comments of the Staff of the Securities
and Exchange Commission (the “Commission”) with respect to the above referenced Form 20-F
for the year ended December 31, 2004.

     We submit the following information and response with respect to each comment contained in the
comment letter. For your convenience, we have set forth each comment from your comment letter in
bold typeface and include our response below it.

     In connection with our responses to the Staff’s comments, the Company acknowledges that (i) it
is responsible for the adequacy and accuracy of the disclosure in its filings; (ii) 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 (iii) it 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.

     We understand that you may have additional questions upon review of our responses or may
request supplemental information. We welcome any questions you may have regarding our responses and
look forward to working with you to enhance our disclosure in future filings with the Commission.

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. These revisions should be
included in your future filings, including your interim filings where applicable.

    We appreciate the Staff permitting the Company to make these changes on a prospective basis.

Aufsichtsratsvorsitzender: Dr. Michael Oltmanns

Amtsgericht Wetzlar: HRB 44

Mr. Rufus Decker

Mr. Gus Rodriguez

Mr. Nudrat Salik

June 21, 2005

Page 2

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
19

    2.

    Please enhance your management’s discussion and analysis disclosures as follows:

    a.

    Please quantify the impact of each factor when multiple factors contribute to
material fluctuations. For example, please quantify your explanations for significant
changes in sales and cost of sales in Germany, Europe (excluding Germany), United
States and Asia as well as for each product category in terms of increases or decreases
in prices, volume, foreign currency and new product introductions. Please also include
an explanation of the underlying reasons for the changes;

    For the information of the Staff, we disclosed net sales by geographic area on page 19, and
net sales by geographic segment on page F-27, of our Form 20-F for the period ended December
31, 2004. Net sales by geographic area include all sales within a particular area, whether
the sales were made by the Company or its subsidiary in the United States. In contrast, net
sales by geographic segment include only those sales made by the particular entity within
the particular location (for example, net sales in the geographic segment of the United
States include only those sales made by the subsidiary in the United States). In future
filings we will disclose in our MD&A both net sales and cost of sales by geographic segment
as set forth below. While we do have information on cost of sales by geographic segment, we
do not have discrete information on cost of sales by geographic area.

    December 31,

    2004

    2003

    (€ in thousands)

    %

    (€ in thousands)

    %

    Net Sales by geographic area

    Germany

    46,962

    30.1

    40,368

    28.0

    Europe (excluding Germany)

    49,349

    31.6

    48,314

    33.5

    United States

    33,140

    21.2

    32,797

    22.8

    Asia

    25,643

    16.4

    21,659

    15.0

    Rest of World

    1,128

    0.7

    880

    0.7

    156,222

    100.0

    144,018

    100.0

    We will include the following in our MD&A in future filings:

    Geographic Segments

    Sales by geographic segments are:

    December 31,

    2004

    2003

    (€ in thousands)

    %

    (€ in thousands)

    %

    Net Sales by geographic segment

    Germany

    72,295

    46.3

    65,974

    45.8

    Europe (excluding Germany)

    46,371

    29.7

    42,459

    29.5

    United States

    33,265

    21.3

    32,716

    22.7

    Rest of World

    4,291

    2.7

    2,869

    2.0

    156,222

    100.0

    144,018

    100.0

Mr. Rufus Decker

Mr. Gus Rodriguez

Mr. Nudrat Salik

June 21, 2005

Page 3

    Sales in Germany increased from € 66.0 million in 2003 to € 72.3 million in 2004 (a 9.6%
increase) due mainly to an increase in the volume of products combined with a more favorable
product mix (a greater percentage of the Company’s high price products were sold in 2004 as
compared to 2003). These increases in sales came primarily from higher systems sales and
growth in the analytical industry market. Sales in the United States increased from $ 37.2
million in 2003 to $ 41.4 million in 2004 (a 11.5% increase) due mainly to the acquisition
of new customers primarily in the industrial and analytical industry markets resulting in
higher volume and more favorable product mix. However, primarily due to the weakness of the
U.S. Dollar, sales in the United States in Euros only increased from € 32.7 million in 2003
to € 33.3 million in 2004 (a 1.7% increase). Sales in Europe (excluding Germany) increased
by € 3.9 million because of an increase in volume of sales for larger projects in the
coating and research and development markets.

    Cost of sales by geographic segments are:

    December 31,

    2004

    2003

    (€ in thousands)

    %

    (€ in thousands)

    %

    Net Cost of Sales Segment

    Germany

    30,797

    32.8

    24,522

    30.0

    Europe (excluding Germany)

    35,293

    37.6

    32,845

    40.2

    United States

    24,530

    26.1

    22,259

    27.2

    Rest of World

    3,286

    3.5

    2,095

    2.6

    93,906

    100.0

    81,721

    100.0

    The cost of sales in Germany increased by 25.6% in 2004 as compared to the prior year due to
our withdrawal from the DVD business in 2004 which adversely affected cost of sales by
approximately € 6.1 million. Without giving effect to this € 6.1 million adverse affect on
cost of sales, the cost of sales in Germany decreased to 34.2% of sales as compared to 37.2%
in 2003.

    The cost of sales in the United States in 2004 increased by € 2.3 million primarily because
of the weak U.S. Dollar. However, as a percentage of sales, the cost of sales in the United
States in 2004 increased by 5.7% as compared to 2003.

    The cost of sales in Europe (excluding Germany) as a percentage of sales in 2004 decreased
by 1.3% as compared to 2003. The cost of sales in the Rest of Word as a percentage of sales
in 2004 increased by 3.6% as compared to 2003.

    Products

    Several factors contributed to the increase in total sales during 2004. First, sales of the
Company’s core product group, turbo pumps, experienced a shift from low priced pumps to high
priced pumps, which led to an increase in the total sales of turbo pumps of € 5.9 million
due to the change in product mix. Second, the backing pumps recorded an increase in volume
which gave rise to a sales increase of € 1.7 million. Third, due to a volume increase in
vacuum instruments and components, the Company generated € 7.3 million more sales in this
product group. In addition, newly introduced pumps generated proceeds of approximately € 1.2
million and are included in turbo pump sales (€ 0.8 million) and in backing pump sales (€
0.4 million).

    Additionally, subsequent to December 31, 2004, the Company approved a plan to withdraw from
its DVD business. Prior to year end, the Company had not met the assets held for sale
criteria in SFAS 144 because board approval was outstanding, but had entered into a
restructuring plan which met the criteria of SFAS 146 (see response to comment 16). The

Mr. Rufus Decker

Mr. Gus Rodriguez

Mr. Nudrat Salik

June 21, 2005

Page 4

    cost of sales were increased by approximately € 6.1 million due to the write down of the
inventories (€ 5.3 million), the write down of the fixed assets (€ 0.3 million) and the
redundancy program (€ 0.5 million).

    Services

    Year ended December 31,

    2004

    2003

    2002

    (€ in thousands)

    Net product sales

    131,211

    118,087

    124,797

    Net service sales

    25,011

    25,931

    26,145

    Total net sales

    156,222

    144,018

    150,942

    Cost of product sales

    (79,150
    )

    (66,162
    )

    (66,838
    )

    Cost of service sales

    (14,756
    )

    (15,559
    )

    (15,687
    )

    Total cost of sales

    (93,906
    )

    (81,721
    )

    (82,525
    )

    Gross profit

    62,316

    62,297

    68,417

    Service sales decreased slightly from € 25.9 million to € 25.0 million. Customers prefer to
purchase new products instead of repairing used products and during good economic
conditions, such as the present conditions, a decrease in service sales is common if, as
with the Company, such decrease occurs at the same time as an increase in product sales.
Cost of service sales as a percentage of service sales decreased slightly from 60.0% to
59.0%.

    Foreign Currency Exchange Conversion

    The Company prepares its consolidated financial statements in Euros. Total net sales were
adversely impacted by € 3.5 million due to the translation of all functional currencies into
Euros (the translation of U.S. dollar sales in Euros accounted for € 3.3 million of this
adverse impact in total net sales).

    b.

    Please also discuss the impact on profitability due to increases in energy,
steel and aluminum raw material prices. Discuss the overall market movements of these
prices during each period, and address any material changes to these prices that have
taken place subsequent to the period end;

    We will include the following in our MD&A in future filings:

    The Company’s continuous management of costs, its long-term cooperation with suppliers (such
cooperation generally has been longer than five years) and the availability of secondary
sources for important raw materials has led to further cost reductions in 2004 which
compensated for increases in energy and raw material prices over the same period of time.
For example, gas prices published by the “Statistische Bundesamt” (Bureau for Federal
Statistics) increased by 24.5% and electricity by 2.3% in the year 2004. In Germany, the
Company has contracts with scheduled price increases for gas of approximately 7.0% and 0.5%
for electricity over the same period of time. The contract for gas does not terminate and
the contract for electricity terminates on December 31, 2006.

    The most important raw material for the Company is aluminium. Approximately 2% of materials
purchased by the Company are aluminium and the remaining 98% of the materials purchased by
the Company consists of several other materials and manufactured components. With respect to
aluminium purchased directly by the Company, Pfeiffer Vacuum has long-term agreements with
suppliers for the purchase of aluminium and has been

Mr. Rufus Decker

Mr. Gus Rodriguez

Mr. Nudrat Salik

June 21, 2005

Page 5

    purchasing from these suppliers for more than five years. These contracts include terms
whereby the Company must purchase defined quantities and qualities within a defined time
frame. These contracts terminate when the defined portions are purchased. The supplier
warrants the defined quality and the Company commits itself to purchase the material at
agreed prices. During 2004, the market price of aluminium increased by 4.3% based on German
published aluminium prices, while the Company incurred no increase in costs compared to 2003
due to the existing contract terms. Additionally, the suppliers of the Company’s
manufactured components have not increased prices of the components based on any increase in
the price of aluminium. Most of these contracts are usually between one to two years.

    c.

    Please clarify where you classified the allowance for doubtful accounts
recorded for the DVD business, and help us understand why the impact of this charge is
not included in your discussion of operating profit for the year ended December 31,
2004. Please also tell us the factors that you considered in determining that the
trade receivables of 1,800,000 Euros associated with the DVD business are not
collectible; and

    In the Form 20-F for the fiscal year ended December 31, 2004, the Company included the
allowance for doubtful accounts in cost of sales, including the allowance for doubtful
accounts related to its DVD business and addressed the impact as part of its discussion of
future sales. In future filings, we will record this expense in the general and
administrative line item of the income statement and reclassify prior year costs for
consistency purposes and will address separately the impact on operating profits. The
receivables related to the DVD business were uncollectible due to the insolvency during the
year of a customer in Canada (€ 1.3 million) and the failure of a customer in Taiwan to pay
for a product (€ 500,000).

    d.

    Please discuss the reasons for the decrease in foreign exchange gains from
2,142,000 Euros in the year ended December 31, 2003 to 377,000 Euros in the year ended
December 31, 2004. Please refer to Item 5 of the Form 20-F.

    We will include the following in our MD&A in future filings:

    The Company’s foreign exchange gains amounted to € 2,928,000 in 2003 and decreased to €
1,332,000 in 2004, offset by foreign exchange losses of € 786,000 in 2003 and € 955,000 in
2004. In 2003, the German parent company had a temporary non-interest-bearing loan amounting
to $10.2 million (€ 11.2 million) from its U.S. subsidiary denominated in U.S. dollar. In
2003, the German parent company paid off this loan and realized a foreign exchange gain of
approximately € 2.6 million, primarily due to the decreased value of the U.S. dollar against
the Euro. In 2004, the Company had no comparable impact similar to the repayment of the
loan. Additionally, the receivables and payables in U.S. dollars decreased to a small level
in 2004 as a result of regular payments, accounting for the majority of remaining changes
between 2003 and 2004.

Contractual Obligations, page 34

    3.

    Please revise your table of contractual cash obligations to include estimated payments under
your pension plans and any interest payments on your debt. Because the table is aimed at
increasing transparency of cash flow, we believe these payments should be included in the
table. Please also disclose any assumptions you made to derive these amounts.

    We will include estimated payments under our pension plans in our table of contractual cash
obligations in future filings. Because we have no bank debt or other interest bearing debt,
we will not have corresponding interest payments.

Mr. Rufus Decker

Mr. Gus Rodriguez

Mr. Nudrat S