SecProbe.io

CORRESP
1
filename1.htm

October 10

October 11, 2005

Mr. Jay Webb

Reviewing Accountant

United States Securities and Exchange
Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

 Re:      Kinetek, Inc.

            Form 10-K for the year
ended December 31, 2004

            Filed March 24, 2005

            File No. 333-19257

Dear Mr. Webb,

I am in receipt of your letter dated
September 26, 2005, which contains comments regarding the Form 10-K filed by Kinetek, Inc. for the Fiscal Year ending December 31, 2004. We have carefully
considered your comments and offer our responses below.

1.    Revenue Recognition, page 26

Staff Comment:

Your disclosure regarding revenue
recognition is too vague. Please expand future filings to describe your revenue
recognition practices in greater detail. To the extent that policy differs among
significant product lines, please make your disclosure product line specific.
Details should be provided to the extent that policy differs among the various
marketing venues used by the Company, i.e. distributors and direct sales force.
As applicable, your disclosures herein in future filings should include details
of discounts, return policies, post shipment obligations, customer acceptance,
warranties, credits, rebates, and price protection or similar privileges and how
these impact revenue recognition.

Response:

The Company has carefully reviewed
the revenue recognition policies of each of its subsidiaries, with consideration
for each of the characteristics cited in the Staff Comment. We agree with the
suggestion that the Revenue Recognition footnote can be expanded to provide more
detail to the reader, and will do so in future filings, beginning with the Form
10-Q for the period ended September 30, 2005.

2.    Section 906 Certifications

Staff Comment:

Please amend your 2004 Form 10-K and
2005 Form 10-Q's to include the certifications required by Section 906 of the
Sarbanes Oxley Act that include the date and the signature of the certifying
officers. We refer you to Question 9 of the FAQ Sarbanes Oxley Act of 2002,
dated November 8, 2002.

Response:

The Company has reviewed Rules
15d-14 and 15d-15 and the staff's response to Question 9 of the FAQ Sarbanes
Oxley Act of 2002, dated November 8, 2002.  The Company is not subject to
Section 15(d) of the Securities Exchange Act of 1934 (the "Exchange Act") and is
not required to file reports under Section 13(a) of the Exchange Act. The
Company files its reports voluntarily pursuant to an indenture covenant.  The
Company believes, therefore, that the above rules do not apply to its filings,
notwithstanding the staff's informal guidance referred to above.  Nevertheless,
the Company will include the certification required by Section 906 of the
Sarbanes Oxley Act in its periodic reports in the future, beginning with the
Form 10-Q for the period ended September 30, 2005.

Kinetek, Inc. hereby acknowledges
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;

      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.

    Please contact me directly if you have further questions or comments
regarding the filings of Kinetek, Inc.

Sincerely,

Daniel Drury

Chief Financial Officer

Kinetek, Inc.