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CORRESP
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      CORRESP

  

              Petersen
                & Fefer

              Attorneys
                at Law

              Telephone
                4126 684-05 00

              Château
                de Barberêche

              Facsimile
                4126 684-0505

              Switzerland
                1783 Barberêche

              Houston
                Voicemail/Fax

              E-mail

              New
                York Voicemail/Fax

              (281)
                596-4545

              jlp@ipo-law.com

              (212)
                401-4750

    August
      17, 2005

    SUBMITTED
      AS CORRESPONDENCE ON THE EDGAR SYSTEM

    H.
      Roger
      Schwall, Assistant Director

    U.S.
      Securities and Exchange Commission

    450
      Fifth
      Street N.W.

    Washington
      DC 20549

    Re: Axion
      Power International, Inc.

    Form
      SB-2
      Registration Statement

    Commission
      File No. 333-124317

    Post-effective
      Amendment No. 2

    On
      August
      15, 2005, the Axion Power International, Inc. filed Post-effective Amendment
      No.
      2 to its Form SB-2 Registration Statement. Based on a earlier telephone message
      that was been left on the undersigned’s voicemail by the staff reviewer on the
      filing, our cover letter requested acceleration of the effectiveness of its
      Form
      SB-2 Registration Statement to 9:00 a.m. on Wednesday, August 17, 2005, or
      as
      soon thereafter as practicable.

    A
      copy of
      our original cover letter filed herewith for your reference.

    The
      timing of the original request was consistent with the requirements of Rule
      461.
      However, for reasons that are not entirely clear, the acceleration request
      set
      forth in our original cover letter was apparently overlooked and the order
      did
      not issue as requested. Therefore, we hereby reiterate our request for an order
      of effectiveness at the earliest practicable date.

    In
      connection with this acceleration request, the undersigned confirm that all
      persons who are responsible for the accuracy and adequacy of the disclosure
      detailed in the filings are aware if their respective responsibilities under
      the
      Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate
      to
      the proposed public offering of the securities specified in the Registration
      Statement, including the responsibility to provide all information investors
      require for an informed decision. Axion Power International, Inc. further
      acknowledges that:

            ·

              Should
                the Commission or the staff, acting pursuant to delegated authority,
                declare the Registration Statement effective, such action does not
                foreclose the Commission from taking any action with respect to the
                filing;

            ·

              The
                action of the Commission or the staff, acting pursuant to delegated
                authority, in declaring the Registration Statement effective, does
                not
                relieve the Registrant from its full responsibility for the adequacy
                and
                accuracy of the disclosure in the Registration Statement;
                and

            ·

              The
                Registrant may not assert any action of the Commission or the staff
                as a
                defense in any proceeding instituted by the Commission or any person
                under
                the federal securities laws of the United
                States.

    We
      hereby
      acknowledge our understanding that the Division of Enforcement has access to
      all
      information

    Please
      do
      not hesitate to contact me directly by telephone or e-mail if I can be of
      further assistance. Our local time in Switzerland is Washington D.C., time,
      plus
      6 hours and my office number is 011-4126-684-0500. If you prefer, you may also
      leave a voice mail message for me at either (212) 401-4750 or (281)
      596-4545.

    Very
      truly yours,

    Petersen
      & Fefer

    /s/

    John
      L.
      Petersen

    Attorney
      at Law

    cc: Thomas
      Granville