SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

  Mail Stop 3030
November 13, 2009
 VIA U.S. MAIL AND FAX (218) 628-3245

 Jon Gerlach Chief Financial Officer Ikonics Corporation 4832 Grand Ave. Duluth, Minnesota 55807

 Re: Ikonics Corporation
  Form 10-K for the year ended December 31, 2008
  Filed March 2, 2009   File No. 000-25727
Dear Mr. Gerlach:

We have reviewed your filings 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 document.  Wh ere indicated, we think you should revise your
document in response to these comments.  If you disagree, we will consider your explanation as
to why our comment is inapplicable or a revisi on is unnecessary.  Please be as detailed as
necessary in your explanation.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclo sure.  After reviewing this information, we
may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filing.  We look forward to working with you in these respects.  We welcome any questions
you may have about our comments or any other aspect of our review.  Feel fr ee to call us at the
telephone numbers listed at the end of th is letter.

Jon Gerlach
Ikonics Corporation
November 13, 2009 Page 2  Form 10-K for the Fiscal Year Ended December 31, 2008

 Fair Value of Financial Instruments, page 19

 1. We note that “The carrying value of the non- marketable equity securities approximated
their estimated fair value based on management’s knowledge of recent sales prices of the non-marketable equity securities”.  In or der to help your investors understand how you
estimate the fair value of your non-marketable equity securities, pleas e explain to us in
greater detail and disclose in your future filings the methodologies and major assumptions used to estimate the fair value of your non-marketable equity securities.
 Revenue Recognition, page 19

 2. We note that “[You] recognize revenue on sale s of products when title passes which can
occur at the time of shipment or when th e goods arrive at the customer location.”
  We
also note on page three that  “[You] currently have approximately 200 domestic and
international distributors.”  In this regard, to  the extent that the policy differs depending
on the passage of title, make your disclosure  more specific to address such different
revenue recognition policies.  Further provide details to the extent that policies differ
among the various marketing venues used by the company, i.e. distributors and reseller.
Also, if the policies vary in different part s of the world those differences should be
discussed.  Please provide details  as it relates to discounts, return policies, post shipment
obligations, customer acceptance, warranties,  credits, rebates, price protection, and
rotation rights or similar privileges and how it impacts revenue recognition.  Also provide an analysis that explains your revenue rec ognition practices and demonstrates that your
policies are SAB 104 and FASB ASC 605 (SFAS 48) compliant.
 Foreign Currency Translation, page 20

 3. We note that your foreign currency transactions  and translation adju stments did not have
significant effects for 2008 and 2007.  Yet we note on page 18 that approximately 31.4%
and 29.6% of net sales were foreign export sales in 2008 and 2007, respectively.  Please
explain to us your accounting policy for fore ign currency transactions and translation
adjustments, citing applicable U.S. GAAP.  Also in your explanation include how you
account for foreign export sales based on your foreign currency translation/transaction
policy.  Revise your future filings to discuss this accounting policy.

Item 2.  Management’s Discussion and Analysis of Financial Conditions and Results of
Operations, page 12

4. We note from your disclosure on page 12 that your investment in iTi is periodically
assessed for an other-than-temporary impair ment.  Also, your disclosure on page 18
appears to imply that your investments in non-marketable equity securities were not
considered to be impaired as of June 30, 2009.  Additionally, we note from your Form 8-

Jon Gerlach
Ikonics Corporation
November 13, 2009 Page 3
K/A filed on October 19, 2009 that you dete rmined as of September 30, 2009 that your
investment in iTi of $919,000 has been fully impaired and accordingly the Company has
recognized an impairment charge of $919,000 during the interim period ended September
30, 2009.  In this regard, please explain in furthe r detail the nature a nd specific timing of
the events or circumstances that occurred  during the third quarter ended September 30,
2009, which caused your investment in iTi to be fully impaired.  Please explain why these events and circumstance that caused you to determine that your investment in iTi was fully impaired were not in existence dur ing your prior two quarters in fiscal year
2009.  Furthermore, if as of June 30, 2009 your investment in iTi was in an unrealized loss position and you concluded that your impairment in iTi was not other than temporary, please provide us with both the positive and negative information considered by you in concluding that your impairment in iT i was not other than te mporary as of June
30, 2009 and fully explain how that informati on differed from the information used in
your other-than-temporary impairment analysis for iTi at September 30, 2009.

As appropriate, please amend your filing and respond to these comments within 10
business days or tell us when you will provide us  with a response.  Pleas e furnish a cover letter
with your amendment that keys your responses to our comments and provides any requested
information.  Detailed cover lette rs greatly facilitate our review .  Please understand that we may
have additional comments afte r reviewing your amendment and responses to our comments.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.
In connection with responding to our comment s, please provide, in writing, a statement
from the company acknowledging that:
‚ the company is responsible for the adequacy and accuracy of the disclo sure 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 federa l securities laws of  the United States.

Jon Gerlach
Ikonics Corporation November 13, 2009 Page 4
 In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.
 You may contact Andri Boerman at (202) 551-3645 or me at (202) 551-3212 if you have
any questions regarding these comments.  In this  regard, do not hesitate to contact Martin F.
James, Senior Assistant Chief Accountant, at (202) 551-3671.           S i n c e r e l y ,                     Jeff Jaramillo          A c c o u n t i n g  B r a n c h  C h i e f