SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

May 18, 2005

Mail Stop 0306

William Lockwood, President
Ovation Products Corporation
395 Dunstable Road
Nashua, New Hampshire 03062

Re:	Ovation Products Corporation
	Registration Statement on Form 10-SB
      Amendment No. 2 Filed April 28, 2005
	File No.  0-51145

Dear Mr. Lockwood:

      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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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.

      Prior comments refers to our letter dated April 7, 2005.
Page
references are to the marked copy furnished.

The Water Purification and Treatment Industry - Page 4

1. Refer to prior comment 3.  Please supplementally provide
support
for the industry data in the first three paragraphs of this
section.
Mark the material to identify the portion(s) you are submitting as
support.  If the sources are proprietary, supplementally
demonstrate
that you have authorization to use this information.

Ovation` Technology - Page 6

2. Refer to prior comment 5.  Please revise the disclosure to be
more
readily understood by readers not familiar with water distillation
technology.  For example, we note the references to "Q Loss" and
"BTU/HR." As another example, clarify the relationship between the
steps on page 6 and the diagram on page 5.

Industrial Waste Stream Applications - Page 8

3. Refer to prior comment 1.  Please discuss the material terms of
the agreement, such as the Schedule 3, the sales price and the
reduced unit cost, and the term of the agreement.  Also, discuss
the
reasons for the delays.

Ovations`s Technology - Page 8

4. Refer to prior comment 9.  Please tell us where you responded
to
the third sentence.

S.J. Electro Systems, Inc. - Page 33

5. Refer to prior comment 2.  Please tell us where you responded
to
the last sentence.

       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.  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 supplemental 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.

      Please contact Alan Morris at (202) 551-3601 or me at (202)
551-3602 with any other questions.

Sincerely,

Thomas Jones
Senior Counsel

cc.  Anna T. Pinedo (Morrison & Foerster)
VIA FAX (212) 468-7900
??

??

??

??

William Lockwood, President
Ovation Products Corporation
May 18, 2005
Page 2

</TEXT>
</DOCUMENT>