SecProbe.io

Mail Stop 3561        March 17, 2008  Via Fax & U.S. Mail

 Ben M. Palmer Chief Financial Officer Marine Products Corporation
2801 Buford Highway, Suite 520
Atlanta, GA 30329

Re: Marine Products Corporation
 Form 10-K for the fiscal year ended December 31, 2007
Filed March 4, 2008
  File No. 001-16263
Dear Mr. Palmer:

We have reviewed your filing and have the following comments.  Unless
otherwise indicated, we think you should revi se your document in future filings in
response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revi sion 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 disclosure.  After
reviewing this information, we may raise additional comments.
  Please understand that the purpose of our review process is to assist you in
your compliance with the applicable disc losure requirements and to enhance the
overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you ma y have about our comments or any other
aspect of our review.  Feel free to call us at the telephone numbers listed at the end of
this letter.
Please respond to confirm that such comments will be complied with, or, if
certain of the comments are deemed inappr opriate, advise the st aff of your reason.
Your response should be submitted in elec tronic form, under the label “corresp” with
a copy to the staff.  Please res pond within ten (10) business days.

Ben M. Palmer
Marine Products Corporation March 17, 2008 Page 2
Form 10-K for the fiscal year ended December 31, 2007
 Consolidated Statements of Cash Flows, page 36

 1. Please revise your consolidated statements of cash flows in future filings to provide separate disclosure of cash flows from sales and maturities of
marketable securities available for sale.  Refer to the guidance outlined in paragraph 18 of SFAS No.115.

Notes to the Consolidated Financial Statements

General
2. We note from your disclosure on page 15 that the Company’s Chairman of
the Board, and his brother, who is also a director of the Company, and certain
companies under their control, control in excess of 50% of the Company’s
voting power.  In this regard, please revise your notes to  the consolidated
financial statements to disclose the nature and existence of this control relationship.  Refer to the requireme nts of paragraph 4 of SFAS No. 57.
 Note 1: Significant Accounting Policies, page 37

- Warranty Costs, page 40
 3. We note that you recognized “Changes to  warranty provision for prior years”
in the amount of $239,000 and $1,985,000 during fiscals 2007 and 2006, respectively.   We note that you in dicate in MD&A on page 24 that the
increase in fiscal 2006 was related to ad justments based on a review of recent
claims experience to reflect the change  in estimated costs per claim, due
primarily to higher labor rates and parts co sts.  Please explain to us in greater
detail the nature and underlying reason( s) for the significant increase during
fiscal 2006 of the warranty provision re lated to prior ye ars and why such
factors were not considered as part of the original estimate.  Your response
should address why you believe it is appr opriate to account for the changes to
provisions for prior years as a change in  accounting estimate rather than as an
error in the financial statements.  Please note that changes in accounting
estimates result from new information where as an error in previously issued financial statements results from math ematical mistakes, mistakes in the
application of GAAP, or oversight or misu se of facts that existed at the time
the financial statement were prepared .  We may have further comment upon
receipt of your response.
 4. Notwithstanding the above, please expl ain why you believe you are still able

Ben M. Palmer
Marine Products Corporation March 17, 2008 Page 3
to make reliable estimates in light of the significant increase in the warranty provisions for prior years made during fiscal 2006.

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  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 all information required
under the Securities Exchange Act of 1934 and that they have provided all
information investors require for an in formed investment decision.  Since the
company and its management are in possessi on of all facts relating to a company’s
disclosure, they are responsible for the accur acy and adequacy of the disclosures they
have made.     In connection with responding to our comments, please provide, in writing, a 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 secu rities laws of the
United States.

In addition, please be advi sed that the Division of Enforcement has access to
all information you provide to the staff of the Division of Corporation Finance in our
review of your filing or in response to our comments on your filing.   You may contact Jean Yu at (202) 551-3305 or myself at  (202) 551-3813 if
you have questions regarding comments on the financial statements and related
matters.
Sincerely,

Linda Cvrkel Branch Chief