SecProbe.io

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 April 30, 2025

Ben Palmer
Chief Executive Officer
MARINE PRODUCTS CORP
2801 Buford Highway NE, Suite 300
Atlanta, GA 30329

 Re: MARINE PRODUCTS CORP
 Registration Statement on Form S-3
 Filed April 23, 2025
 File No. 333-286707
Dear Ben Palmer:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Eranga Dias at 202-551-8107 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

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 MARINE PRODUCTS CORPORATION 2801 BUFORD HIGHWAY NE, SUITE 300 ATLANTA, GEORGIA 30329 ​ ​ April 30, 2025 ​ VIA EDGAR TRANSMISSION ​ United States Securities and Exchange Commission Division of Corporation Finance 100 F. Street, N.E. Washington, D.C. 20549 Attn: Eranga Dias ​ Re: Marine Products Corporation Registration Statement on Form S-3 File No. 333-286707 ​ Acceleration Request Requested Date: May 5, 2025 Requested Time: 5:00 p.m. Eastern Time ​ Ladies and Gentlemen: ​ Pursuant to Rule 461 under the Securities Act of 1933, as amended, Marine Products Corporation (the “Company”) hereby requests that the above-referenced Registration Statement on Form S-3 (File No. 333-286707) (the “Registration Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable, or at such later time as the Company or its counsel may orally request via telephone call to the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”). The Company hereby authorizes Joe Alley of Arnall Golden Gregory LLP, counsel for the Company, to make such request on the Company’s behalf. ​ The Company requests that it be notified of the effectiveness of the Registration Statement by telephone to Joe Alley of Arnall Golden Gregory LLP at (404) 873-8688 or via email at joe.alley@agg.com. ​ Please direct any questions or comments regarding this acceleration request to Joe Alley at (404) 873-8688. ​ Sincerely, ​ Marine Products Corporation ​ ​ By: /s/ Michael L. Schmit                                      Michael L. Schmit Vice President, Chief Financial Officer, Treasurer and Corporate Secretary

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mpc_corresp

July
26, 2021

VIA EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100 F
Street, NE

Washington,
DC 20549-4561

Attn:
Eiko Yaoita Pyles

Re:

Marine Products
Corporation

Registration
Statement on Form S-3

Filed
June 24, 2021

File
No. 333-257365

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the Securities Act of 1933, as amended, Marine
Products Corporation hereby requests that the Securities and
Exchange Commission accelerate the effectiveness of the
above-referenced Registration Statement to 4:30 p.m., Eastern Time,
on July 29, 2021, or as soon thereafter as
practicable.

Thank
you for your assistance. Should you have any questions, please
contact Joe Alley of Arnall Golden Gregory LLP at (404)
873-8688.

Very
truly yours,

Marine
Products Corporation

/s/ Ben M. Palmer

Ben M.
Palmer

Vice
President, Chief Financial

Officer
and Corporate Secretary

United States securities and exchange commission logo
June 28, 2021
Ben M. Palmer
Chief Financial Officer
Marine Products Corporation
2801 Buford Highway NE
Suite 300
Atlanta, Georgia 30329
Re:Marine Products Corporation
Registration Statement on Form S-3
Filed June 24, 2021
File No. 333-257365
Dear Mr. Palmer:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Eiko Yaoita Pyles at 202-551-3587 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

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    secresponse090816.htm

Direct phone: 404.873.8706

Direct fax: 404.873.8707

E-mail: robert.dow@agg.com

www.agg.com

September 8, 2016

VIA EDGAR

Mr. Nicholas P. Panos

Senior Special Counsel

Office of Mergers and Acquisitions

U.S. Securities and Exchange Commission

Mail Stop 3628

100 “F” Street, N.E.

Washington, D.C. 20549-3628

Re:      Marine Products Corporation

Schedule TO

Filed August 26, 2016

File No. 005-61531

Dear Mr. Panos:

On behalf of our client, Marine Products Corporation (the “Company,” or “Marine Products”), we are submitting this letter in response to the comments of the Staff of the Securities and Exchange Commission (the “Commission”) in a letter dated September 6, 2016 (the “Comment Letter”) with respect to above referenced Schedule TO (the “Schedule TO”).  For the convenience of the Staff, each of the Staff’s comments is restated in italics prior to the response to such comment.  The Company intends to file Amendment No. 1 to the Schedule TO to provide additional disclosure in response to the Comment Letter.

General

1.

Please provide the information required pursuant to General Instruction C to Schedule TO with regard to each executive officer and director of the Company, or advise. Also provide the information required under Item 1003(a) of Regulation M-A pursuant to Item 3 of Schedule TO with regard to these.

Response:

The Offer to Purchase filed with the original Schedule TO includes most of the items referenced in your comment. There were two items missing, specifically, the addresses of each officer and director and a statement that none of the officers and directors has any of the specified plans or proposals. Attached is a chart showing the location of each item within the Offer

to Purchase. Also attached is a draft Addendum to the Offer to Purchase to be filed with Amendment No. 1 providing the two additional items.

Source and Amount of Funds, page 22

2.

We read the consolidated balance sheet included within the Form 10-Q filed August 1, 2016. Please advise us what financial resources constitute “working capital.” In addition, please revise to disclose any alternative financing arrangements or alternative financing plans in the event the primary financing plan falls through. If no such arrangements exist, please revise to so state. Refer to Item 1007(b) of Regulation M-A.

Response:

The Company expects to fund the tender offer through a combination of cash flow from operations and the sale of its highly liquid short-term and long-term marketable securities. The Company does not have an alternative financing plan due to the sufficiency of funds that will be available from the sale of such marketable securities. We have provided additional disclosure on the point in the draft Addendum to the Offer to Purchase to be filed with Amendment No. 1.

The Company has authorized us to confirm on its behalf that they acknowledge that (a) the Company is responsible for the adequacy and accuracy of the disclosure in the filings, (b) staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings, and (c) 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. Attached is a letter signed by Ben M. Palmer, Chief Financial Officer of Marine Products, on behalf of the Company.

If you have any questions, please do not hesitate to contact me at (404) 873-8706.

Very truly yours

ARNALL GOLDEN GREGORY LLP

/s/ Robert F. Dow

Robert F. Dow

cc:           Mr. Ben M. Palmer

Jonathan Golden, Esq.

B. Joseph Alley, Jr., Esq.

Enclosures:           Letter from Marine Products Corporation

Chart of Disclosure Items

Draft Addendum to Offer to Purchase

2801 Buford Highway, Suite 520, Atlanta, GA  30329. Telephone:  (404) 321-7910    Facsimile:  (404) 321-5483

September 8, 2016

On behalf of Marine Products Corporation, I acknowledge that (a) the Company is responsible for the adequacy and accuracy of the disclosure in the filings, (b) staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings, and (c) 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.

MARINE PRODUCTS CORPORATION

By:

/s/ Ben M. Palmer

Name:

Ben M. Palmer

Title:

Vice President and Chief Financial Officer

Date:

September 8, 2016

Chart of Disclosure Items

Marine Products Corporation

Tender Offer - Required Disclosure Items Raised in Comment letter

Reg. M-A  Item No.

Description of Item

Included in OTP filed 8/26/16?

Additional disclosure required

1003(a)

Name and address of each person

No

Addresses added for D&Os

1005(e)

D&O agreements involving securities

Yes p. 26

N/A

1006(a)

Purpose of transaction

Yes p. 12

N/A

1006(b)

Whether securities retired, etc.

Yes p. 14

N/A

1006(c)

Plans (for D&O)

No

Added statement that no such plans exist for D&Os

1007(a)

Source of funds

Yes p. 22

Additional discussion provided on source

1007(b)

Conditions

Yes p. 20

N/A

1007(c)

Borrowed funds

Yes p. 22

N/A

1008(a)

Securities ownership

Yes p. 24-25

N/A

1008(b)

Securities transactions

Yes p. 25

N/A

Draft Addendum to Offer to Purchase dated August 26, 2016

Updated as of September 8, 2016

The Offer to Purchase (“Offer to Purchase”) attached to the Schedule TO (“Schedule TO”) of Marine Products Corporation (the “Company”) filed on August 26, 2016, is amended as indicated below. Except as expressly set forth herein, this Amendment does not reflect events occurring after the date of the Schedule TO or modify or update any of the other disclosures contained therein in any way other than as required to reflect the amendments discussed below.

2.

Purpose of the Offer; Certain Effects of the Offer

Section 2 is amended to add the following:

Based on our records and information provided to us by our affiliates, directors and executive officers, neither we nor, to the best of our knowledge, any of our affiliates, directors or executive officers, have any plans related to the events discussed on p. 14 of the Offer to Purchase.

 9.

Source and Amount of Funds

Section 9 is amended to read as follows:

We will use cash flow from operations and funds from selling our marketable securities to fund the purchase of the shares tendered in the Offer and to pay fees and expenses related to the Offer. Assuming that the Offer is fully subscribed for 3,200,000 shares, we expect the aggregate purchase price for the shares, together with all related fees and expenses, to be approximately $29.1 million ($31.8 million if the Offer is increased to 3,500,000 shares). For the second quarter of 2016, we had positive cash flow from operations of approximately $10.8 million.  As of June 30, 2016 we held highly liquid short-term and long-term marketable securities with an aggregate market value of $47.4 million. We do not have an alternative plan for financing the tender offer due to the sufficiency of  funds that will be available from the sale of such marketable securities. The Offer is not conditioned upon financing, although the Offer is subject to certain conditions. See Section 7.

11.

Interests of Directors and Executive Officers; Transactions and Arrangements Concerning the Shares

Section 11 is amended to add the following:

Listed below are the names and addresses of the Officers, Directors and holders of more than 5% of the common stock of the Company:

R. Randall Rollins

Chairman of the Board

2170 Piedmont Road, NE

Atlanta, Georgia 30324

Gary W. Rollins

Vice Chairman and Chief Executive Officer, Rollins, Inc.

2170 Piedmont Road, NE

Atlanta, Georgia 30324

Gamco Investors, Inc.

One Corporate Center

Rye, NY 10580

Richard A. Hubbell

President and Chief Executive Officer

2801 Buford Highway NE, Suite 520

Atlanta, Georgia 30329

Ben M. Palmer

Vice President, Chief Financial Officer and Treasurer

2801 Buford Highway NE, Suite 520

Atlanta, Georgia 30329

Linda H. Graham

Vice President and Secretary

2170 Piedmont Road, NE

Atlanta, Georgia 30324

Bill J. Dismuke

Director

2170 Piedmont Road, NE

Atlanta, Georgia 30324

Larry Prince

Director

2170 Piedmont Road, NE

Atlanta, Georgia 30324

Henry Tippie

Director

2170 Piedmont Road, NE

Atlanta, Georgia 30324

James B. Williams

Director

2170 Piedmont Road, NE

Atlanta, Georgia 30324

September 6, 2016

Via E -mail
Mr. Ben M. Palmer
Chief Financial Officer
Marine Products Corporation
2801 Buford Highway, Suite 520
Atlanta, GA 30329

Re: Marine Products Corporation
 Schedule TO -I
Filed  August 26 , 2016
File No. 005 -61531

Dear Mr. Palmer :

We have limited our review of the filing to those issues we have addressed in our
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amen ding your filing, by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts and circumstances or do not believe an amendment is
appropriate, please tell u s why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.

General

1. Please provide the information required pursuant to General Instruction C to Schedule
TO with regard to each executive officer and director of the Company , or advise .  Also
provide the information required under Item 1003(a) of Regulation M -A pursuant to Item
3 of Schedule TO with regard to these individuals.

Source and Amount of Funds, page  22

2. We read  the consolidated balance sheet included within the Form 10 -Q filed August 1,
2016 .  Please advise us what financial resources constitute  “working capital. ”  In
addition, please revise to disclose any alternative financing arrangements or alternative
financing plans in the event the primary financing plan falls through.  If no such
arrangements  exist , please revise to so state.  Refer to Item 1007(b) of Regulation M -A.

Mr. Ben M . Palmer
Marine Products Corporation
September 6, 2016
Page 2

 We urge all person s who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the  Company and its management are
in possession of all facts relating to the Company’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures it has made.

 In responding to our comments, please provide a written statement from t he Company
acknowledging that:

 the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with res pect 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.

Please contact Justin A. Kisner, Staff Attorney, at (202) 551 -3788, or me at (202) 551 -
3440 , if you have any questions regarding our comments.

Sincerely,

 /s/ Nicholas P. Panos

Nicholas P. Panos
Senior Special Counsel
Office of Mergers and Acquisitions

cc: Via E -mail
 Robert F. Dow, Esq.
 Arnall Golden Gregory LLP

August 3, 2015

Richard Hubbell
Chief Executive Officer
Marine Products Corporation
2801 Buford Highway NE, Ste. 520
Atlanta, GA 30329

Re: Marine Products Corporation
 Form 10-K for Fiscal Year Ended December 31, 2014
Filed February 27, 2015
File No. 001-16263

Dear Mr. Hubbell :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or 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.  We u rge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ J. Nolan McWilliams

J. Nolan McWilliams
Attorney -Advisor
Office of Transportation and Leisure

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 July 31, 2015

VIA EDGAR

Mr. J. Nolan McWilliams

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

    RE:
    Marine Products Corporation

        Form 10-K for Fiscal Year Ended December 31,
        2014

        Filed February 27, 2015

        File No. 001-16263

Dear Mr. McWilliams:

This letter provides the
Company’s response to the comment in your letter dated July 7, 2015 about the Company’s referenced filing. In an effort
to facilitate the Staff’s review, we have repeated the comment prior to setting forth the Company’s response thereto.

Item 1A. Risk Factors, page 12

 1. Please refer to section twenty-nine of
your amended and restated by-laws dated October 28, 2014. To the extent this provision remains in force after August 1, 2015, please
confirm that in your next periodic report you will discuss the validity of this section in light of the new Section 102(f) of the
Delaware General Corporation Law and include appropriate risk factor disclosure about the fee-shifting provision contained in your
amended by-laws and the impact this provision may have on your shareholders. The risk factor should also address the types of actions
subject to fee-shifting, including whether you intend to apply the provision to claims under the federal securities laws.

Response: The Company amended
its by-laws to repeal section twenty-nine of the Company’s amended and restated by-laws. Accordingly, no further discussion
of this provision of the by-law is required.

The Company acknowledges
that:

 · the company is responsible for the adequacy
and accuracy of the disclosure in the filing;

 · 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

                                                            Mr. J. Nolan McWilliams

                                                            July 31, 2015

                                                            Page 2

 · 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.

Please direct any further comments or questions
to me at (404) 321-2149.

    Sincerely,

    /s/ Ben M. Palmer

    Ben M. Palmer, Chief Financial Officer

 cc: Mr. Richard A. Hubbell

    Mr. Stephen D. Fox

July 7, 2015

Richard Hubbell
Chief Executive Officer
Marine Products Corporation
2801 Buford Highway NE, Ste. 520
Atlanta, GA 30329

Re: Marine Products Corporation
 Form 10-K for Fiscal Year Ended December 31, 2014
Filed February 27, 2015
File No. 001-16263

Dear Mr. Hubbell :

We have reviewed your filing an d have the following comment .  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to this comment , we may have  additional comments.

Item 1A. Risk Factors, page 12

1. Please refer to section twenty -nine of your amended and restated by -laws dated October
28, 2014.   To the extent this provision remains in force after August 1, 2015, please
confirm that in your next periodic report you will discuss the validity of this section in
light of the new Section 102(f) of the Delaware General Corporation Law and inclu de
appropriate risk factor disclosure about the fee -shifting provision contained in your
amended bylaws and the impact this provision may have on your shareholders.   This risk
factor should also address the types of actions subject to fee -shifting, includi ng whether
you intend to apply the provision to claims under the federal securities laws.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Sec urities Exchange Act of
1934 and all applicable Exchange Act rules 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.

Richard Hubbell
Marine Products Corporation
 July 7, 2015
 Page 2

  In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in resp onse 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 l aws of the United States.

Please contact Tonya K. Aldave at (202) 551 -3601  or me at (202) 551 -3217  with any
questions.

Sincerely,

 /s/ J. Nolan McWilliams

J. Nolan McWilliams
Attorney -Advisor

Mail Stop 3561
       April 1, 2008  Via Fax & U.S. Mail

 Ben M. Palmer Chief Financial Officer Marine Products Corporation 2801 Buford Highway, Suite 520 Atlanta, GA 30329

Re: Marine Products Corporation
 Form 10-K for the fiscal year ended December 31, 2007
Filed March 4, 2008
  File No. 001-16263
Dear Mr. Palmer:

 We have completed our review of your Fo rm 10-K and related filings and have no
further comments at this time.
         S i n c e r e l y ,           L i n d a  C v r k e l         B r a n c h  C h i e f

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    marineprodcorr33108.htm

      2801
Buford Highway, Suite 520

      Atlanta,
Georgia 30329

      Phone:
404.321.2140

      Fax:
404.321.5483

    VIA
EDGAR

    March 31,
2008

    Ms. Linda
Cvrkel

    Division
of Corporation Finance

    Securities
and Exchange Commission

    100 F
Street, N.E.

    Washington,
DC 20549-7010

              Re:

              Marine
      Products Corporation

              Form
      10-K for the Fiscal Year ended December 31, 2007

              Filed
      March 4, 2008

              File
      No. 001-16263

              Your
      comment letter dated March 17, 2008

    Dear Ms.
Cvrkel:

    This
letter provides the Company’s responses to your comments about the above
referenced filing.  In an effort to facilitate the Staff’s review, we
have repeated each of the comments prior to setting forth the Company’s response
thereto in the same order that they appeared in your letter.

    Form 10-K for the year ended
December 31, 2007

    Consolidated Statements of
Cash Flows, page 36

              1.

              Please
      revise your consolidated statements of cash flows in future filings to
      provide separate disclosure of cash flows from sales and maturities of
      marketable securities available for sale.  Refer to the guidance
      outlined in paragraph 18 of SFAS No.
115.

    RESPONSE

    In future
filings the Company’s consolidated statements of cash flows will provide
separate disclosure of cash flows from sales of marketable securities available
for sale and cash flows from maturities of marketable securities available for
sale.

      Division
of Corporation Finance

        Securities
and Exchange Commission

        March 31,
2008

        Page
2

    Notes to the Consolidated
Financial Statements

    General

              2.

              We
      note from your disclosure on page 15 that the Company’s Chairman of the
      Board, and his brother, who is also a director of the Company, and certain
      companies under their control, control in excess of 50% of the Company’s
      voting power. In this regard, please revise your notes to the consolidated
      financial statements to disclose the nature and existence of this control
      relationship. Refer to the requirements of paragraph 4 of SFAS No.
      57.

    RESPONSE

    In future
filings, the Company will provide the following additional
disclosure:

    A group
that includes the Company’s Chairman of the Board, R. Randall Rollins and his
brother Gary W. Rollins, who is also a director of the Company, and certain
companies under their control, controls in excess of fifty percent of the
Company’s voting power.

    Note 1: Significant
Accounting Policies, page 37

    - Warranty Costs, page
40

              3.

              We
      note that you recognized “Changes to warranty provision for prior years”
      in the amount of $239,000 and $1,985,000 during fiscals 2007 and 2006,
      respectively.  We note that you indicate in MD&A on page 24
      that the increase in fiscal 2006 was related to adjustments based on a
      review of recent claims experience to reflect the change in estimated
      costs per claim, due primarily to higher labor rates and parts costs.
      Please explain to us in greater detail the nature and underlying reason(s)
      for the significant increase during fiscal 2006 of the warranty provision
      related to prior years and why such factors were not considered as part of
      the original estimate. Your response should address why you believe it is
      appropriate to account for the changes to provisions for prior years as a
      change in accounting estimate rather than as an error in the financial
      statements. Please note that changes in accounting estimates result from
      new information where as an error in previously issued financial
      statements results from mathematical mistakes, mistakes in the application
      of GAAP, or oversight or misuse of facts that existed at the time the
      financial statement were prepared. We may have further comment upon
      receipt of your response.

    RESPONSE

    The 2006
change in the warranty provision related to prior years of $1,985,000 was
recorded as a change in accounting estimate because it resulted from new
information.  This change in the warranty provision was not treated as
an error in previously issued financial statements because it did not result
from mathematical mistakes, mistakes in the application of GAAP, or oversight or
misuse of facts that existed at the time the financial statements were
prepared.

      Division
of Corporation Finance

        Securities
and Exchange Commission

        March 31,
2008

        Page
3

    It is
important to note that depending upon dealer inventory turns, sales from dealer
inventory to retail customers typically occur several months after our sale of
the boat to the dealer.  Warranty claims generally arise after the
boat is sold to the retail customer for up to one to two years for specified
components and within approximately three years for structural
defects.  Accordingly, there is an extended time delay between the
Company recording the sales and estimated warranty provision, and the warranty
claim being reported to the dealer by the retail customer and the eventual
receipt of the claim by the Company.  Factors used in estimating the
Company’s warranty provision include, among other variables, warranty terms in
effect, the Company’s decisions about enforcement of those terms and
qualification of claim types over time, defects in parts and materials, the
volume and mix of boat sales, and the ultimate cost of labor and parts at the
time warranty work is expected to be completed.

    Two
factors resulted in the 2006 change in the warranty provision related to prior
years; (1) the decline in industry sales and profitability for manufacturers and
dealers and, (2) the continuing higher cost of worldwide commodity prices
impacting our component costs, and therefore, warranty replacement
parts.

    During
2005, industry unit sales began to decline impacting the profitability of both
manufacturers and dealers.  We believe this had an impact on the
frequency and size of warranty claims processed by dealers because warranty work
was viewed as an additional source of revenues.  To remain competitive
during the decline in industry sales and respond to the negative impact on
warranty claims experience, the Company considered various business alternatives
to control our warranty claims while improving dealer and customer
satisfaction.  As a result, we developed incentive programs providing
dealers the opportunity to qualify for higher tiered warranty-related labor
rates if, among other things, they achieved specified future customer service
levels.  The number of dealers expected to qualify for this incentive
and the related cost impact were considered in 2005 when estimating both the
current period warranty provision and the change in the warranty provision
related to prior years.  However, in 2006 the timing of dealers
qualifying for increased labor rates and their level of achievement was higher
than expected.  This was confirmed through review of the claims
received in 2006.  The incentive program was highly successful in that
improved customer satisfaction was achieved, but it resulted in a higher than
expected warranty claims cost related to labor.  Therefore, we
recognized the additional estimated cost of these higher labor rates during
2006.

    Historically,
prices for commodities critical to our business, such as steel and petroleum,
have been cyclical and based on domestic levels of demand.  Commodity
prices were increasing in 2005.  With the slowdown in domestic
consumer discretionary spending which was also impacting our industry and other
recreational product industries, we expected a corresponding decline in
commodity prices that are critical to the cost of our components and warranty
replacement parts.  In 2006, however, with continued strong economic
growth from other world economies, notably China and India, we expected the
costs to remain at these higher levels, and accordingly, the Company recognized
this additional estimated cost of warranty replacement costs during
2006.

      Division
of Corporation Finance

        Securities
and Exchange Commission

        March 31,
2008

        Page
4

    In
summary, during 2006 the warranty provision related to prior years (noted as a
percentage of net sales) was recorded to reflect a new estimate of approximately
2.0% for 2004 and 2.0% for 2005 compared to initial estimates recorded of
approximately 1.7% in 2004 and 1.6% in 2005.

    Please
note that the Company considered this new information regarding higher warranty
cost trends together with its quality initiatives in estimating the warranty
provision as a percentage of net sales occurring in 2006 of 1.8% and in 2007 of
1.9%.

              4.

              Notwithstanding
      the above, please explain why you believe you are still able to make
      reliable estimates in light of the significant increase in the warranty
      provisions for prior years made during fiscal
  2006.

    RESPONSE

    As part
of the Company’s focus on quality, the Company regularly reviews warranty claims
data and other related information.  We use this information to make
business decisions about improvements in our manufacturing process, management
of its warranty claims and related payments, and to make management judgments
about accounting for warranty.  We believe the knowledge obtained from
these reviews provides a solid basis for making reasonable estimates of the cost
of future warranty claims.

    The
Company acknowledges the following:

              ·

              the
      Company is responsible for the adequacy and accuracy of the disclosure in
      the filing;

              ·

              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.

              Very
      truly yours,

              /s/
      Ben M. Palmer

              Ben
      M. Palmer

    cc:           Ms.
Jean Yu

Mail Stop 3561        March 17, 2008  Via Fax & U.S. Mail

 Ben M. Palmer Chief Financial Officer Marine Products Corporation
2801 Buford Highway, Suite 520
Atlanta, GA 30329

Re: Marine Products Corporation
 Form 10-K for the fiscal year ended December 31, 2007
Filed March 4, 2008
  File No. 001-16263
Dear Mr. Palmer:

We have reviewed your filing and have the following comments.  Unless
otherwise indicated, we think you should revi se your document in future filings in
response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revi sion 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 disc losure 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 ma y 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.
Please respond to confirm that such comments will be complied with, or, if
certain of the comments are deemed inappr opriate, advise the st aff of your reason.
Your response should be submitted in elec tronic form, under the label “corresp” with
a copy to the staff.  Please res pond within ten (10) business days.

Ben M. Palmer
Marine Products Corporation March 17, 2008 Page 2
Form 10-K for the fiscal year ended December 31, 2007
 Consolidated Statements of Cash Flows, page 36

 1. Please revise your consolidated statements of cash flows in future filings to provide separate disclosure of cash flows from sales and maturities of
marketable securities available for sale.  Refer to the guidance outlined in paragraph 18 of SFAS No.115.

Notes to the Consolidated Financial Statements

General
2. We note from your disclosure on page 15 that the Company’s Chairman of
the Board, and his brother, who is also a director of the Company, and certain
companies under their control, control in excess of 50% of the Company’s
voting power.  In this regard, please revise your notes to  the consolidated
financial statements to disclose the nature and existence of this control relationship.  Refer to the requireme nts of paragraph 4 of SFAS No. 57.
 Note 1: Significant Accounting Policies, page 37

- Warranty Costs, page 40
 3. We note that you recognized “Changes to  warranty provision for prior years”
in the amount of $239,000 and $1,985,000 during fiscals 2007 and 2006, respectively.   We note that you in dicate in MD&A on page 24 that the
increase in fiscal 2006 was related to ad justments based on a review of recent
claims experience to reflect the change  in estimated costs per claim, due
primarily to higher labor rates and parts co sts.  Please explain to us in greater
detail the nature and underlying reason( s) for the significant increase during
fiscal 2006 of the warranty provision re lated to prior ye ars and why such
factors were not considered as part of the original estimate.  Your response
should address why you believe it is appr opriate to account for the changes to
provisions for prior years as a change in  accounting estimate rather than as an
error in the financial statements.  Please note that changes in accounting
estimates result from new information where as an error in previously issued financial statements results from math ematical mistakes, mistakes in the
application of GAAP, or oversight or misu se of facts that existed at the time
the financial statement were prepared .  We may have further comment upon
receipt of your response.
 4. Notwithstanding the above, please expl ain why you believe you are still able

Ben M. Palmer
Marine Products Corporation March 17, 2008 Page 3
to make reliable estimates in light of the significant increase in the warranty provisions for prior years made during fiscal 2006.

********
  We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that  the filing includes all information required
under the Securities Exchange Act of 1934 and that they have provided all
information investors require for an in formed investment decision.  Since the
company and its management are in possessi on of all facts relating to a company’s
disclosure, they are responsible for the accur acy 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
filing;
‚ 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 secu rities laws of the
United States.

In addition, please be advi sed 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 Jean Yu at (202) 551-3305 or myself at  (202) 551-3813 if
you have questions regarding comments on the financial statements and related
matters.
Sincerely,

Linda Cvrkel Branch Chief