March 7, 2018
Mr. Terence O’Brien
Branch Chief
Office of Manufacturing and Construction
U.S. Securities and Exchange Commission
100 F Street, N.E. Mail Stop 4631
Washington, D.C. 20549
Re: International Baler Corporation
Form 10-K for the year ended October 31, 2017, filed January 26, 2018
File No. 0-14443
Ladies and Gentlemen
This letter responds to comments of the Staff of the Securities and Exchange Commission contained in the letter dated March 6, 2018 regarding the International Baler Form 10-K for the fiscal year ended October 31, 2017. For the staff’s convenience we have recited the staff’s comment and provided the Company’s response to comment immediately thereafter.
Controls and Procedures, page 11
| 1. | Please confirm to us, if true, that management concluded that its disclosure controls and procedures were effective as of October 31, 2017 pursuant to Item 307 of Regulation S-K. Please ensure such conclusion is clearly stated in your filings. |
We acknowledge the staff’s comment. We confirm that management had concluded that its disclosure controls and procedures were effective as of October 31, 2017. In future filings we will confirm that disclosure controls and procedures were effective as of the period ending date of filing.
International Baler Corporation
William E. Nielsen
President
Chief Financial Officer
International Baler Corporation | Tel: | 904-358-3812 |
| 5400 Rio Grande Avenue | 800-231-9286 | |
| P.O. Box 6922 (zip 32236) | Fax: | 904-358-7013 |
| Jacksonville, Florida 32254 | Email: | sales@intl-baler.com |
| Web: | www.intl-baler.com |