SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
April 1, 2005

Mail Stop 0510

By U.S. Mail and facsimile to (770) 303-8807

Barbara Blackford, Esq.
General Counsel
Superior Essex Inc.
150 Interstate North Parkway
Atlanta, Georgia 30339

      Re: 	Superior Essex Inc.
Form 10-K for the year ended December 31, 2004
      File No. 000-50514

Dear Ms. Blackford:

      This is to advise you that we reviewed only those portions
of
the above filing that relate to the evaluation of disclosure
controls
and procedures.  No further review of the filing has been or will
be
made.

      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.

Item 9A.  Controls and Procedures, page 47

1. We note the disclosure that your controls and procedures have
been
designed to ensure that information "is recorded, processed,
summarized and reported within the time periods specified in the
SEC`s rules and forms."  Please clarify in future filings, if
true,
that your disclosure controls and procedures are also designed to
ensure that information required to be disclosed in the reports
that
you file or submit under the Exchange Act is accumulated and
communicated to your management, including your CEO and CFO, to
allow
timely decisions regarding required disclosure.  See Exchange Act
Rule 13a-15(e).

2. We note your statement that "[a] system of controls, no matter
how
well designed and operated, cannot provide absolute assurance that
the objectives of the system of controls are met, and no
evaluation
of controls can provide absolute assurance that all control issues
and instances of fraud, if any, within a company have been
detected."
In future filings, please revise to state clearly, if true, that
your
principal executive officer and principal financial officer
concluded
that your disclosure controls and procedures are effective at the
reasonable assurance level.  Refer to Section II.F.4 of
Management`s
Reports on Internal Control Over Financial Reporting and
Certification of Disclosure in Exchange Act Periodic Reports,
Release
No. 33-8238, available on our website at
www.sec.gov/rules/final/33-
8238.htm.

      Please provide us with a supplemental response that
addresses
each of our comments and notes the location of any corresponding
revisions made in your filing.  Please also note the location of
any
material changes made for reasons other than responding to our
comments.  Please file your supplemental response on EDGAR as a
correspondence file.  We may raise additional comments after we
review your responses.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy 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 filings;
* 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 securities laws of the United States.

      In addition, please be advised 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 Matt Franker, Staff Attorney, at (202) 824-
5495
or Chris Edwards, Senior Staff Attorney, at (202) 942-2842 with
questions.  Alternatively, you may contact me at (202) 942-1950.

Sincerely,

Pamela A. Long
Assistant Director

??

??

??

??

Barbara Blackford, Esq.
Superior Essex Inc.
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>