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CORRESP
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November 22, 2005

Via EDGAR

Mr. Rufus Decker

Branch Chief

Division of Corporation Finance

The United States Securities and Exchange
Commission

450 Fifth Street

Washington, D.C.  20549-7010

  RE:

  Superior Essex Inc.

  Form 10-K for the Fiscal Year
  ended December 31, 2004

  Forms 10-Q for the Fiscal
  Quarters ended March 31, 2005, June 30, 2005 and September 30, 2005

  File No. 0-50514

Dear
Mr. Decker:

                We submit this letter in
response to comments received from the Staff of the SEC in your letter dated
November 18, 2005 (the “Comment Letter”) with respect to the Form 10-K of
Superior Essex Inc. for the year ended December 31, 2004 and the Forms 10-Q of
Superior Essex Inc. for the quarters ended March 31, 2005, June 30, 2005 and
September 30, 2005. The discussion below is presented in order of the numbered
comments in the Comment Letter and we have reproduced the comments for ease of
reference.

                The Company’s responses to the
Staff’s comments are as follows:

Form 10-K for the year ended December 31, 2004

General

1.               Where a comment
below requests additional disclosures or other revisions to be made, please
show us in your response what the revisions will look like.  These revisions should be included in your
future filings, including your interim filings where applicable.

        Response to comment 1:

        Our responses herein indicate, where
applicable, the revisions to be included in future filings.

Management’s
Discussion and Analysis of Financial Condition and Results of Operations, page
29

2.               Copper-adjusted
net sales and consolidated sales adjusted for a constant cost of copper,
excluding the impact of the Belden and Nexans asset acquisition are non-GAAP
financial measures.  Rather than
presenting these measures, you should consider disclosing with quantification
the impact that each of these items had on the GAAP amounts in each period
presented.  In the event that you
disclose the non-GAAP financial measures, please revise your disclosure to
include:

•                              A presentation, with equal
or greater prominence, of the most directly comparable financial measure
calculated and presented in accordance with GAAP.

•                              A reconciliation of the
non-GAAP measure to its most directly comparable financial measure calculated
and presented in accordance with GAAP.

•                              A statement as to how you
use the non-GAAP measure and why you believe it provides meaningful information
to investors.

Please refer to Item 10(e)(i) of Regulation S-K.  Please also refer to SEC Release 33-8176 and
the Frequently Asked Questions regarding the use of non-GAAP financial measures
for additional guidance.

        Response to comment 2:

        The second, third and fourth paragraphs
under the caption Results of Operations - Year Ended
December 31, 2004 Compared to the Year Ended December 31, 2003 will be revised in
the 2005 Form 10-K as follows to eliminate references to copper-adjusted net
sales excluding the impact of the Belden and Nexans asset acquisitions:

        Consolidated sales for the
year ended December 31, 2004 were $1,424.6 million, an increase of
44% as compared to consolidated sales of $988.0 million for the year ended
December 31, 2003. Sales for 2004 were significantly impacted by the
increase in copper prices. Sales adjusted for a constant cost of copper
increased $183.6 million, or 18%, for 2004 compared to the prior year.
Sales in our communications cable segment for the year ended December 31,
2004 also included approximately $115 million ($99 million on a
copper-adjusted basis) attributable to customer contracts acquired in the
Belden Asset Acquisition. Sales in our magnet wire and distribution segment for
2004 included approximately $14.4 million ($12 million on a copper-adjusted
basis) attributable to customer contracts acquired in the Nexans Asset
Acquisition. Consolidated net sales and sales adjusted for a constant cost of
copper increased 13% and 11%, respectively as a result of the Belden Asset
Acquisition and the Nexans Asset Acquisition.
The remaining increase in consolidated sales adjusted for a constant cost of
copper reflects volume increases in all of our business segments.

        Sales for our
communications cable segment for 2004 increased 56% compared to sales for 2003.
Sales adjusted for a constant cost of copper increased 39%. Sales and copper
adjusted sales increased approximately 34% and 29%, respectively, as a result
of the estimated impact of the Belden Asset Acquisition. The remaining increase
in sales for our communications cable segment adjusted for a constant cost of
copper of 10% reflects increased demand for our copper OSP cable product lines,
which we believe is due in part

2

to higher
spending levels to support deferred maintenance by some of our major telephone
company customers as well as demand resulting from damage caused by the
hurricanes in the southeastern United States in the second half of 2004. These
increases in copper OSP cable demand were offset in part by increased
deployment of fiber optic cable by one of our major copper OSP customers pursuant
to an announced plan to increase the use of fiber optic cable further
downstream in their network. We also experienced strong growth in our premises
and fiber optic cable products supported by growing investment in information
technology, including new and upgraded computer systems and associated wiring
and an increase in our market share.

        Sales for our magnet wire
and distribution segment were $611.5 million for the year ended
December 31, 2004, an increase of 28% as compared to the prior year including 3% attributable to the estimated impact
of the Nexans Asset Acquisition. On a copper-adjusted
basis, sales for the year increased 8% over the prior year, including 3%
attributable to the estimated impact of the Nexans Asset Acquisition. The
increase reflects volume increases in both our Essex Brownell distribution
business and to a lesser degree our major OEM customer base particularly
related to the power and energy sector a portion of which we believe is
associated with hurricane related repairs.

        Additionally, we will comply with the
disclosures required by Item 10(e)(i) of Regulation S-K with respect to all
non-GAAP disclosures contained in future filings.

3.               Please discuss
and analyze the business reasons for the changes between periods in operating
income (loss) for each of your segments.

        Response to comment 3:

        The ninth paragraph under the caption Results of Operations - Year Ended December 31, 2004 Compared to the
Year Ended December 31, 2003 will be revised in the 2005 Form 10-K as
follows to discuss the business reasons for changes between periods in
operating income (loss) for each of our segments:

        The following table sets forth information
regarding our operating income for the periods indicated. We measure our
segment operating performance based primarily on segment operating income,
excluding restructuring and other charges and asset impairments.

  Superior

  Essex Inc.

  Combined

  Superior

  Essex Inc.

  Superior

  TeleCom Inc.

  Year Ended

  December 31,

  2004

  Year Ended

  December 31,

  2003

  Period

  November 11,

  2003 to

  December 31,

  2003

  Period

  January 1,

  2003 to

  November 10,

  2003

  (in thousands)

  Operating income (loss):

  Communications Cable

  $

  30,690

  $

  17,603

  $

  942

  $

  16,661

  Magnet Wire and
  Distribution

  30,338

  19,117

  (92

  )

  19,209

  Copper Rod

  1,740

  (173

  )

  376

  (549

  )

  Corporate and other

  (17,041

  )

  (11,427

  )

  (1,455

  )

  (9,972

  )

  Restructuring
  and other charges and asset impairments

  (2,030

  )

  (9,822

  )

  (1,184

  )

  (8,638

  )

  $

  43,697

  $

  15,298

  $

  (1,413

  )

  $

  16,711

3

        Operating
income for the communications cable segment increased $13.1 million in 2004
compared to 2003 due to increased gross profit primarily attributable to
increased sales volume, including sales attributable to the Belden Asset
Acquisition, and a more favorable product mix. Communications cable operating
income was also positively impacted by a decrease in depreciation expense of
approximately $4.0 million primarily resulting from the application of
fresh-start accounting. These positive factors were partially offset by a
shortfall in recovering second quarter 2004 increases in copper costs as
previously discussed, integration costs of $3.9 million incurred in connection
with the Belden Asset Acquisition, amortization charges of $0.8 million related
to intangible assets acquired in the Belden Asset Acquisition and higher sales costs
and commissions in 2004 associated with increased sales volumes. Operating
income for our magnet wire and distribution segment increased $11.2 million due
primarily to increased gross profit resulting from increased sales volumes,
including sales attributable to the Nexans Assset acquisition, lower
depreciation charges of $2.9 million primarily resulting from the application
of fresh-start accounting and the implementation of price surcharges in the
fourth quarter of 2004. Selling, general and administrative expenses related to
the magnet wire and distribution segment were also positively impacted by lower
depreciation charges of $0.8 million primarily resulting from the application
of fresh-start accounting. The copper rod segment’s operating income increased
$1.9 million in 2004 compared to 2003 due primarily to the impact of increased
sales volumes and lower depreciation charges of $0.8 million primarily
resulting from the application of fresh-start accounting. Copper rod segment
sales consist primarily of external sales of processed copper rod that is not
used for internal production and allow for fixed cost recovery at gross profit
margins that are generally break even. Copper rod volumes fluctuate from period
to period due to changes in internal consumption needs and external market
conditions. Corporate and other charges consist primarily of parent company and
executive payroll costs, including stock-based compensation charges, corporate
headquarters costs and corporate professional fess and compliance costs. The
increase in corporate and other costs for the year ended December 2004 compared
to 2003 is primarily due to corporate stock-based compensation charges ($1.2
million) and professional fees and costs related to compliance with Section 404
of the Sarbanes-Oxley Act ($3.1 million). Consolidated operating income in 2003
included restructuring and other charges of $9.8 million compared to
$2.0 million of such charges in 2004, the components of which are
discussed above.

        Additionally, the eighth paragraph under
the caption Results of Operations - Year Ended
December 31, 2004 Compared to the Year Ended December 31, 2003 will be revised in
the 2005 Form 10-K as follows to more clearly identify the reportable segments
to which restructuring and other charges relate:

        Superior TeleCom incurred
$2.3 million of restructuring and other charges for the period
January 1, 2003 to November 10, 2003 primarily relating to ongoing
closure activities at the communications cable segment’s Elizabethtown and
Winnipeg facilities offset by foreign currency transaction gains of
$1.5 million related to Superior TeleCom’s communications
cable

4

Canadian subsidiary. Restructuring and other charges for the period
January 1, 2003 to November 10, 2003 also included pre-petition
professional fees of $3.6 million incurred in connection with preparation
for Superior TeleCom’s Chapter 11 filings, $1.1 million of severance
payments related to a workforce reduction at Superior TeleCom’s magnet wire and distribution U.K.
subsidiary, $2.3 million of asset impairments resulting from closure of
one of Superior TeleCom’s copper rod segment’s continuous copper rod casting
lines and $0.8 million of asset impairments resulting from the write-off
of abandoned equipment at Superior Telecom’s magnet wire and distribution U.K.
subsidiary. Restructuring and other charges for the year ended
December 31, 2004 and the period November 11, 2003 to
December 31, 2003 were $2.0 and $1.2 million, respectively, and
consisted primarily of ongoing professional fees related to the implementation
of the plan of reorganization and employee retention and severance payments
under plans established by Superior TeleCom in connection with its bankruptcy
proceedings.

4.               Please quantify
in your management’s discussion and analysis the extent to which the
fluctuation in each statement of operations line item is due to unique factors
such as, but not limited to, the following:

•                  Revenues and
cost of revenues of the Belden asset acquisition,

•                  Revenues and
cost of revenues of the Nexans asset acquisition,

•                  The integration
costs of the Belden and Nexans asset acquisition,

•                  The shortfall
in recovering increases in copper costs through contractual price adjustments
in the second quarter of 2004,

•                  Lower
amortization and depreciation charges due to the application of fresh-start
accounting,

•                  Implementation
of price surcharges in the fourth quarter of 2004, and

•                  Impact of
higher natural gas prices, freight costs and copper producer premiums.

Refer
to Item 303(a) of Regulations S-K.

        Response to comment 4:

The fluctuation in revenues
attributable to the Belden and Nexans assets acquisitions is discussed in the
response to comment 2 above. We do not believe it is possible to meaningfully
quantify the impact on cost of goods sold of these asset acquisitions as the
majority of sales to the acquired customer base were comprised of product
manufactured in our existing facilities. Any allocation of gross profit
increases resulting from improved capacity due to the Belden and Nexans asset
acquisitions and other factors would be arbitrary at best. The impact of the
Nexans asset acquisition integration costs was not significant.

The sixth paragraph under
the caption Results of Operations - Year
Ended December 31, 2004 Compared to the Year Ended December 31, 2003
will be revised in the 2005 Form 10-K to quantify
the effect on gross profit of the Belden integration costs and lower
amortization and depreciation charges due to the application of fresh-start
accounting as follows:

                For
the year ended December 31, 2004, gross profit was $138.6 million, an
increase of 29% as compared to the prior year primarily attributable to
increased volume in our communications cable and magnet wire and distribution
segments and lower depreciation charges in 2004 resulting from the application
of fresh-start reporting. The gross profit margin in 2004 was 9.7%
compared to 10.9% for 2003. The comparative decline in gross profit margin
reflects the effects of increased

5

copper
prices on sales. Gross profit margin on a copper-adjusted basis was 11.7%
for the year ended December 31, 2004 compared to 10.8% for the year ended
December 31, 2003. Copper-adjusted gross profit margins in our
communications cable business increased by 0.3% for 2004 compared to the prior
year due to improved capacity utilization resulting from higher sales volumes, a
more favorable product mix and lower
depreciation charges of $3.7 million primarily resulting from the application
of fresh-start accounting. These positive factors were partially offset by
integration costs of $3.9 million (including $1.8 million of accelerated
depreciation charges associated with displaced machinery and equipment)
incurred in connection with the Belden Asset Acquisition and an estimated $1.5
million shortfall in recov