Mail Stop 0306


March 23, 2005



Via Facsimile and U.S. Mail

Richard L. Jones
Chief Financial Officer
Microwave Filter Company, Inc.
6743 Kinne Street
East Syracuse, NY  13057


	Re:	Microwave Filter Company, Inc.
		Form 10-K for the fiscal year ended September 30, 2004
			Filed December 23, 2004
		Form 10-Q for the fiscal quarter ended December 31, 2004
		File No. 000-10976

Dear Mr. Jones:

      We have reviewed your response dated March 8, 2005 and have
the
following additional comments.  Where indicated, we think you
should
revise your documents 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.  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 comment or on any other
aspects
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.



Form 10-K/A as of September 30, 2004

1. We note your 10-K/A filed March 8, 2005 does not include the
certifications required by Rules 13a-14(a) and 15d-14(a) of the
Exchange Act.  Please amend your 10-K/A filed March 8, 2005 to
include the required certifications.

Form 10-Q/A as of December 31, 2004

2. We note your 10-Q/A filed March 8, 2005 does not include the
certifications required by Rules 13a-14(a) and 15d-14(a) of the
Exchange Act.  Please amend your 10-Q/A filed March 8, 2005 to
include the required certifications.


* * * * * * * *


      As appropriate, please amend your September 30, 2004 Form
10-K
and your December 31, 2004 Form 10-Q and respond to these comments
within 10 business days or tell us when you will provide us with a
response.  You may wish to provide us with marked copies of the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested supplemental information.  Detailed cover letters
greatly facilitate our review.  Please file your cover letter on
EDGAR.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.

      You may contact Kevin Vaughn, Staff Accountant, at (202)
824-
5387 or me at (202) 942-2861 if you have questions regarding these
comments.  In this regard, do not hesitate to contact Daniel
Gordon,
the Branch Chief, at (202) 942-2813.


							Sincerely,


							Kate Tillan
							Reviewing Accountant


??

??

??

??

Mr. Richard Jones
Microwave Filter Company, Inc.
March 23, 2005
Page 1


1