SecProbe.io

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Mail Stop 6010

July 8, 2005

Dustin M. Shindo
Chairman of the Board of Directors,
President and Chief Executive Officer
Hoku Scientific, Inc.
2153 North King Street, Suite 300
Honolulu, Hawaii 96819

Re:	Hoku Scientific, Inc.
	Amendment No. 3 to Registration Statement on Form S-1
      Filed July 6, 2005
	Registration No. 333-124423

Dear Mr. Shindo:

      We have reviewed your filing and have the following
comments.
Where 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 revision 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 disclosure
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 may 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.

Amendment No. 3 to Registration Statement on Form S-1

The Offering, page 4

1. Please refer to prior comment 3 of our letter dated June 23,
2005.
We note that you addressed this comment previously by including in
your disclosure in Amendment No. 2 that the number of shares of
common stock that will be outstanding after the offering "includes
543,750 shares of common stock that are subject to repurchase."
It
appears that this disclosure has been eliminated in Amendment No.
3.
Please revise to include the disclosure or tell us why you believe
it
is properly excluded.

Management`s Discussion and Analysis..., page 26

Financial Operations Review, page 26

Sanyo Electric Co., Ltd., page 27

2. Please clarify, if true, that you do not anticipate receiving
any
further revenue under your current agreement with Sanyo.

Financial Statements, page F-1

Note 1. Summary of Significant Accounting Policies and Practices,
page F-7

Revenue Recognition, page F-7

Please refer to prior comments 8 and 9 from our July 1, 2005
letter.
Please respond to the following comments:

3. It appears that the 2005 Nissan agreement and the Navy contract
both include the provision of engineering and development services
and options to purchase products.  Since you have selected
different
revenue recognition methods for each of these contracts, please
provide us with your analysis of why.  Discuss the similarities
and
differences of the terms of the agreements that resulted in your
revenue recognition method selection.

4. With respect to the 2005 Nissan agreement, we note that you
will
record the service portion of the agreement on a straight-line
basis
once you begin those services.  Please clarify in your response
and
disclosure when this period ends.  That is, clarify whether the
straight-line period extends to the termination date of the
contract
because you will perform services through that date.  Please tell
us
why the straight-line method is appropriate.  That is, address
whether or not this method is consistent with the way in which you
will perform your obligations under the agreement.

5. Also, we note that your June 23, 2005 response refers to
services
related to both engineering and testing.  In that response you
stated
that engineering service revenue would be recognized on a
straight-
line basis over the period you performed the testing services,
since
the testing services are the last deliverable.  Discuss when you
will
perform the engineering services and when you will deliver the
products.  Explain how you were able to determine that the testing
services are the last deliverable, including whether or not you
could
be required to deliver products after you begin the testing
services.

6. We also note that you will record revenue related to products
on a
straight-line basis from the date that the product is delivered
through the end of the term of the agreement.  You have previously
told us that you cannot determine a fair value for your products,
but
you can for your services.  It appears that the timing of the
delivery of the products may occur prior to, during, or after you
perform the services.  We note from your prior response that you
cannot segregate the service and product components of this
arrangement into separate units of accounting under paragraph 9 of
EITF 00-21.  That is, you cannot determine the fair value of an
undelivered element.  As such, please tell us why you are
recording
revenues for each element using these methods if you cannot
segregate
the elements.  That is, it appears that you could record product
revenue prior to the date that the testing phase begins.

7. With respect to the Navy contract, please discuss your
consideration of the guidance in footnotes 2 and 3 of EITF 00-21.

8. Please clarify when you will recognize revenue under the
following
scenarios.  (A) You have completed the engineering services under
the
contract but the Navy has not decided about the additional options
under the agreement.  Discuss whether or not there is a
contractual
time limit under which they must decide whether or not to elect
the
options.  Explain how you would treat circumstances under which
you
receive no response.  That is, consider a scenario where the Navy
neither elects nor rejects the options.  Please also address the
same
scenario assuming you complete the first option and are awaiting
the
Navy`s decision on the second option.  (B) You have completed the
engineering services and the Navy has elected both options under
the
contract.  Under this scenario it appears that the last
deliverable
is the twelve-month testing of the fuel cell plants.  As such,
explain how you will use the proportional performance method of
revenue recognition under this scenario.  Please tell us and
disclose
the basis under which you will measure that performance.  (C)
You
have completed the engineering services and the Navy has elected
only
option one under the contract.  Under this scenario it appears
that
the last deliverable is the delivery of fuel cell plants.  As
such,
explain how you will record revenues.  Please tell us and disclose
the basis under which you will measure that performance.  Please
also
tell us whether or not your auditors consulted with their national
office regarding the recognition of revenue under the Navy
contract.

* * *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Julie Sherman at (202) 551-3640 or Kaitlan
Tillan, Assistant Chief Accountant, at (202) 551-3604, if you have
questions regarding our comments on the financial statements and
related matters.  Please contact Tim Buchmiller at (202) 551-3635
or
me at (202) 551-3617 with any other questions.

      Sincerely,

      Russell Mancuso
      Branch Chief

cc:	Timothy J. Moore, Esq.
	John T. McKenna, Esq.
	Nicole C. Deiger, Esq.
	Scott B. Paul, Esq.
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Dustin H. Shindo
Hoku Scientific, Inc.
July 8, 2005
Page 4

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