SecProbe.io

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June 3, 2005

Kate Tillan
Kevin Kuhar
Angela Crane
Division of Corporate Finance
Securities and Exchange Commission
Mail Stop 6010
Washington, D.C.  20549

       Re:      International Isotopes Inc.
                Form 10-KSB for the Fiscal Year-Ended December 31, 2004
                Filed March 31, 2005
                Form 10-QSB for the Fiscal Quarter Ended March 31, 2005
                File No. 000-22923

Ladies and Gentlemen:

On behalf of  International  Isotopes Inc., set forth below are our responses to
your comments made in your comment letter dated May 23, 2005.  Your comments are
also included below (in italics) for your convenience.

Form 10-KSB for the Year Ended December 31, 2004

Item 8A Controls and Procedures, page 14

1.   Please respond to the following comments regarding your disclosure controls
     and procedures.

     o   We note  your  statement  that your  principal  executive  officer  and
         principal   financial   officer  "have  concluded  that  the  company's
         disclosure  controls  and  procedures  are  effective  to  ensure  that
         material  information relating to the company was made known to them by
         others within the company, particularly during the period in which this
         Annual  Report on Form 10-KSB was being  prepared."  It does not appear
         that your  certifying  officers  have  reached a  conclusion  that your
         disclosure controls and procedures are effective.  Please revise future
         filings  to  address   your   officers'   conclusions   regarding   the
         effectiveness of your disclosure controls and procedures.

     o   We note your statement in your March 31, 2005 Form 10-Q that a "control
         system,  no matter how well  conceived and  operated,  can provide only
         reasonable,  not absolute,  assurance that the objectives of the system
         are met." Please revise future filings to state clearly,  if true, that
         your  disclosure  controls  and  procedures  are  designed  to  provide
         reasonable  assurance  of  achieving  their  objectives  and that  your
         principal  executive officer and principal  financial officer concluded
         that your  disclosure  controls and  procedures  are  effective at that
         reasonable assurance level. In the alternative, remove the reference to
         the level of assurance  of your  disclosure  controls  and  procedures.
         Please  refer to  Section  II.F.4 of  Management's  Report on  Internal
         Control Over  Financial  Reporting and  Certification  of Disclosure in
         Exchange Act Periodic  Reports,  SEC Release No. 33-8238,  available on
         our website at http:www.sec.gov/rules/final/33-8238.htm.

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International Isotopes Inc. Response:

     The requested disclosure will be included in future filings.

Note 1, Description of Business and Significant Accounting Policies, page 26

Significant Accounting Policies, Page 26

(h) Revenue Recognition, page 28

2.   Please respond to the following comments:

     o   Please tell us and disclose in future filings your revenue  recognition
         policy for services, or tell us why this disclosure is not applicable.

     o   Please tell us and disclose in future  filings how you  considered  the
         revenue  recognition  criteria  in SAB Topic  13.A in  determining  the
         amount of revenue to recognize.

     o   Please  tell us and  disclose  in future  filings  why  shipment is the
         appropriate point for revenue recognition.

International Isotopes Inc. Response:

     o   Nearly all of the revenue  from our  services  segment is derived  from
         topaz processing.  The revenue is recognized per the terms of the topaz
         processing  contract.  Any other services provided by the Company would
         also be performed and revenue  recognized in accordance  with the terms
         of a specific  services  contract.  The  requested  disclosure  will be
         included in future filings.

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     o   Our product revenue  recognition  uses the  recognition  policy per the
         criteria in SAB 13 in that:

         1.  There is persuasive evidence that an arrangement exists because all
             of the Company's sales are  contractual.  Signed  agreements are in
             place  for  all  sales  either  in  the  form  of a  contract  or a
             signed/issued purchase order.

         2.  Delivery has occurred because, per the terms of the contract, title
             to the material transfers FOB shipping point. The risks and rewards
             of  ownership  transfer to the buyer at the point of  shipment.  As
             such  it is  appropriate  to  recognize  revenue  at the  point  of
             shipment. There are no additional agreements that allow for unusual
             return  provisions or unusual payment terms. No uncertainty  exists
             as to the  obligation of the customer for the product.  At shipment
             the revenue recognition process is complete.

         3.  The price is fixed or  determinable  per the terms of the contract.
             There are no  cancellation  or  termination  provisions  that would
             indicate  the product  might be for  demonstration  or an otherwise
             incomplete transaction.

         4.  Collectibility  is reasonably  assured because the sales process is
             contractual  in  nature.  The  terms  of the  contract  are met and
             collectibility is reasonably assured.

             The requested disclosure will be included in future filings.

     o   Shipment is the appropriate  point for revenue  recognition of products
         because  title to the product  transfers to the customer at the time of
         shipment per the terms of the contract.

         The requested disclosure will be included in future filings.

Note 3. Inventories, page 31

3.   We note that your work-in process  inventories  include cobalt-60  isotopes
     that are located in the U.S.  federal  government's  Advanced Test Reactor.
     Please explain to us in more detail the nature of your  cobalt-60  isotopes
     and how you value those isotopes as of December 31, 2004.

International Isotopes Inc. Response:

     The  cobalt-60  isotopes are produced by sealing  cobalt metal pellets into
     aluminum housings (referred to as "targets") and placing these targets into
     the Advanced  Test Reactor  ("ATR").  Several years of  irradiation  in the
     reactor are  required for the cobalt to reach the desired  activity  level.
     Each target has a distinct  identification number engraved on it. The costs
     for  production of the cobalt are tracked on a per target basis and include
     1) the  materials  and  labor for  fabrication  of the  target,  2) the ATR
     contractor  labor  charges  for  handling  the  target,   and  3)  the  ATR
     irradiation  charges  on the  target.  The sum of all cobalt  target  costs
     represents the total cobalt work-in-process  inventory. The Company carries
     the cost of each target at the lower of accumulated cost or market value of
     the isotopes.  When the cobalt from a target is sold, the Company  expenses
     the total costs listed in inventory for that target as cost of goods sold.

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Note 10. Sale of Assets, page 39

4.   We see that you sold real estate in  Waxahachie,  TX for the  assumption of
     $345,295 of related debt on the property.  Please tell us how you accounted
     for this transaction, citing the accounting guidance upon which you relied,
     and the net  carrying  amount of the assets  sold.  Please also tell us and
     disclose in future  filings the amount of gain or loss recorded on the sale
     and how you  classified  the gain or loss in your  statements of operations
     and why.

International Isotopes Inc. Response:

     During the year ended  December 31, 2001, in connection  with  discontinued
     operations  in Texas,  the Company took a $1,774,118  impairment  charge on
     certain  assets  relating  to the  Texas  operations.  A  portion  of  this
     impairment  charge was allocated to the  Waxahachie  property  reducing its
     carrying  value to $345,295,  representing  the remaining  amount owed on a
     note payable (the "Secured Note") which is secured by the property.

     In January 2003,  the Waxahachie  property was sold for $345,295,  with the
     purchaser  assuming the balance owing on the Secured Note as consideration.
     Because the Company remains obligated under the Secured Note,  however,  it
     has a  contingent  liability  until the  Secured  Note is paid off in full.
     Because the property had previously been written down through an impairment
     charge, no gain or loss was recognized at the time the property was sold.

     In  accordance  with FASB No. 45,  Guarantor's  Accounting  and  Disclosure
     Requirements for Guarantees,  Including Indirect Guarantees of Indebtedness
     of Others,  the Company has  recognized a $10,000  liability in  connection
     with its  continuing  obligations  under the Secured Note.  Such  liability
     represents  the  estimated  costs the Company  would incur to refinance the
     Secured Note should the purchaser of the property default on its obligation
     to pay off the  Secured  Note.  If the  purchaser  does so default  and the
     Company  becomes  obligated for the remaining  balance on the Secured Note,
     the Company would be entitled to  possession of the property,  the value of
     which is in excess of the remaining balance of the Secured Note.

     The Company  acknowledges  that (i) we are responsible for the adequacy and
     accuracy of the  disclosure in our periodic and current  reports filed with
     the Commission; (ii) comments from the Commission's staff or changes to our
     disclosure  made in response to the staff's  comments do not  foreclose the
     Commission from taking any action with respect to the filing;  and (iii) we
     may not assert  comments  from the  Commission's  staff as a defense in any
     proceeding  initiated  by the  Commission  or any person  under the federal
     securities laws of the United States.

Sincerely,

Steve Laflin
President and Chief Executive Officer

Cc   Chris Grosso - Director
     Ralph Richart - Chairman of the Board
     Steve Avis - Hansen Barnet and Maxwell
     Kevin Killpack - Poston Denney & Killpack
     Shannon Hartwell - Perkins Coie LLP

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