SecProbe.io

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Mail Stop 6010

July 18, 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. 4 to Registration Statement on Form S-1
      Filed July 13, 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. 4 to Registration Statement on Form S-1

Part II of Registration Statement

1. Please allow adequate time for review and resolution of any
comments on exhibits that you have not yet filed.

Exhibit 5.1

2. We note that your counsel, in rendering its opinion, examined
and
relied upon, among other things, your Amended and Restated
Certificate of Incorporation and Bylaws "as currently in effect"
and
that the date of the opinion is July 12, 2005.  We also note that
you
have filed as exhibits to your registration statement a form of
Amended and Restated Certificate of Incorporation and a form of
Amended and Restated Bylaws that will each be effective upon the
closing of your offering.  Please file an opinion which addresses
the
legality of the shares to be issued under the certificate of
incorporation and bylaws that will be in effect upon the closing
of
your offering.

* * *

      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 18, 2005
Page 2

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