September 6, 2005

Mr. Dennis J. Welhouse
Lexington Precision Corp.
40 East 52nd Street
New York, NY  10022

Re:	Lexington Precision Corp.
Form 10-K for the fiscal year ended December 31, 2004
Form 10-Q for the fiscal quarter ended June 30, 2005
      File No. 0-3252

Dear Mr. Welhouse:

      We have reviewed your filings and have the following
comments.
We have limited our review to only disclosures concerning
repurchase
of debt and discontinued operations and will make no further
review of
your documents.   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 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 comments or on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-Q for the Quarter Ended June 30, 2005

Discontinued Operations
1. We note that you have sold substantially all of the die casting
division`s equipment and inventory and certain other assets;
however,
it does not appear that you have sold the facility, but you expect
to
lease the facility to the purchaser with an option to buy.  Based
on
the guidance provided by paragraphs 30 and 42 of SFAS 144, it does
not
appear that you have satisfied the requirements to classify this
facility as discontinued operations.  Please demonstrate to us why
you
believe that the facility should continue to be reported as
discontinued operations as permitted under SFAS 144.

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

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filing includes all information required under the Securities and
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decisions.  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.

	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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

	In addition, please be advised 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 Mindy Hooker at (202) 551-3732 or me at
(202)
551-3768 if you have questions regarding these comments.

							Sincerely,



							John Cash
							Branch Chief
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Mr. Dennis J. Welhouse
Lexington Precision Corp.
September 6, 2005
Page 3 of 3





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

         DIVISION OF
CORPORATION FINANCE