Mail Stop 7010

      July 27, 2005

Mr. Yvon Pierre Cariou
Dynamic Materials Corporation
5405 Spine Road
Boulder, Colorado 80301

      Re:	Dynamic Materials Corporation
		Form 10-K for the year ended December 31, 2004
      File No. 1-14775

Dear Mr. Cariou:

      We have reviewed your response letter dated June 17, 2005
and
have the following additional comments.  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 information so we may better understand
your disclosure.  After reviewing this information, we may raise
additional comments.

FORM 10-K FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004

Financial Statements for the Year Ended December 31, 2004

Note 8 - Discontinued Operations, page 53

1. We note your response to comment 8 from our letter dated May 4,
2005.  Please refer to paragraph 42 of SFAS 144, which indicates
that
the classification of a component of an entity as discontinued
operations is only appropriate if that component has been disposed
of
or is classified as held for sale, and if it meets the additional
criteria of having its operations and cash flows eliminated from
your
ongoing operations and you have no significant continuing
involvement
in the operations of the component.  Please provide us with the
following additional information to help us understand how you
have
met the criteria of this paragraph:

* It does not appear that you have disposed of your Spin Forge
division since you retain the majority of its assets on your
books,
and you are receiving rental income from leasing or subleasing
those
assets to a third party.  If you believe that your lease and
sublease
of these assets constitutes a sale, please tell us the accounting
guidance that you relied upon to make that determination and
provide
us with any applicable analysis of how you meet the criteria of
such
guidance.  Specifically address in your analysis the fact that the
term of the lease for Spin Forge`s manufacturing equipment and
tooling is less than three years.

* We note that your sublease agreement with Aerojet offered them
the
option to purchase your bargain purchase option on Spin Forge`s
land.
We further note that Aerojet`s option expires on August 1, 2005.
Please tell us if Aerojet exercised this option.  If they did not
exercise this option, please address your retention of the bargain
purchase option in any analysis you provide us that supports your
belief that you have disposed of Spin Forge`s assets.

* If you believe that your lease and sublease of Spin Forge`s
assets
meet the criteria of paragraph 30 of SFAS 144 to be classified as
held for sale, please provide us with a detailed analysis of how
these leases meet each of the criteria.  You should specifically
address the impact of the multiple-year lease terms on the
criteria
of this paragraph.

* If you can demonstrate that Spin Forge`s assets have either been
disposed of or can be classified as held for sale, then please
provide us with a detailed analysis of how this transaction meets
the
criteria of paragraph 42(a) and 42(b).  In this regard, we note
that
you will continue to receive income from Spin Forge`s operations
in
the form of rental payments, and we note that you retain the legal
title to the manufacturing equipment that is used by this
business.

*	*	*

		Please respond to these comments within 10 business
days,
or tell us when you will provide us with a response.  Please
provide
us with a response letter that keys your responses to our comments
and provides any requested information.  Detailed letters greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

      If you have any questions regarding these comments, please
direct them to Jennifer Thompson, Staff Accountant, at (202) 551-
3737
or, in her absence, to the undersigned at (202) 551-3768.

      Sincerely,



      John Cash
      Accounting Branch Chief
Mr. Yvon Pierre Cariou
Dynamic Materials Corporation
July 27, 2005
Page 1


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE