SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE
       October 18 , 2013

Via E -mail
Mr. Andrew Puhala
Senior Vice President and  Chief Financial Officer
American Electric  Technologies, Inc.
6410 Long Drive
Houston, Texas 77087

 Re: American Electric Technologies, Inc.
  Form 10 -K for the fis cal year ended December 31, 2012
  Filed March  28, 2013
  File No. 000 -24575

Dear Mr. Puhala :

We have reviewed your filing 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.  In some of our comments, we may
ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten busine ss days  by providing the requested
information, or by advising us when you will provide the requested response. If you do
not believe our comments apply to your facts and circumstances , please tell us why in
your response.

After reviewing the information you pr ovide in response to these comments, we
may have additional comments.

Form 10 -K for t he Fiscal Year Ended December 31 , 2012

Financial Statements

Note 6. Advances to and Investments in Foreign Joint Ventures’ Operations, page F -1

1. We note the significan ce of your investments in joint ventures to your financial
statements.  In future filings, please revise to include all disclosures required by
Rule 8 -03(b)3 of Regulation S -X for your equity investees.  For example, we note
that you have not included gross profit in your disclosures.

Andrew Puhala
American Electric Technologies, Inc.
October 18 , 2013
Page 2

 2. In light of the significance of your investments in joint ventures please explain to
us how you considered whether providing separate full equity method investee
financial statements for the more significant investees would be material to an
investor’s understanding of your financial statements.  We note that net sales of
BOMAY increased from $53.6 million in fiscal 2011 to $84.6 million in fiscal
2012 and exceeded your cons olidated net sales each period and net equity income
from foreign joint ventures’ operations represented most of your net income for
fiscal 2012.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exchange Act rules require.  Since the compa ny
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 responding to our comments, please provide a written 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.

           You may contact Praveen Karthol y at (202) 551 -3778 or me  at (202) 551 -3676  if
you have questions regarding comments on the financial statements and related matters.
You may also contact Martin James, Senior Assistant Chief Accountant, at (202) 551 -
3671 with any other questions.

Sincerely,

/s/ Brian Cascio

Brian Cascio
Acco unting Branch Chief