SecProbe.io

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      November 2, 2004

via U.S. mail and facsimile

Barbara L. Blackford, Esq.
Executive Vice President, General Counsel and Secretary
Superior Essex Inc.
150 Interstate North Parkway
Atlanta, Georgia 30339

Re:	Superior Essex Inc.
	Registration Statement on Form S-1/A
	Filed on November 1, 2004
	File No. 333-118950

Dear Ms. Blackford,

      This is to advise you that we have reviewed only those
portions
of the above registration statement that relate to the selling
securityholder disclosures.  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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form S-1

Principal and Selling Stockholders, page 73
1. Please revise your disclosures to identify the natural person
or
persons who have voting or investment control over the company`s
securities for Apollo Management V, L.P. and Babson Capital
Management, LLC.
Closing Comments

      No further review of the registration statement has been or
will be made.  All persons who are by statute responsible for the
adequacy and accuracy of the registration statement are urged to
be
certain that all information required under the Securities Act of
1933 has been included.

      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
for
an informed decision.  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.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      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.

      Please direct any questions to Tamara Brightwell at (202)
824-
5221.  You may also direct questions to the undersigned Assistant
Director, who supervised the review of your filing, at (202) 942-
1950.

								Sincerely,

								Pamela Long
								Assistant Director

      Cc:  	Jack P. Jackson, Esq.
      	Proskauer Rose LLP
      	1585 Broadway
      	New York, New York 10036-8299
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Barbara L. Blackford
Superior Essex Inc.
November 2, 2004
Page 2

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

         DIVISION OF
CORPORATION FINANCE

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