VIA FACSIMILE AND U.S. MAIL 	October 19, 2005 Robert P. Dowski Chief Financial Officer The Allied Defense Group, Inc. 8000 Towers Crescent Drive, Suite 260 Vienna, Virginia 22182 	RE:	Form 10-K for Fiscal Year Ended December 31, 2004 File No. 1-11376 Dear Mr. Dowski: We have completed our review of your Form 10-K and related filings and have no further comments at this time. If you have any further questions regarding our review of your filings, please direct them to Ernest Greene, Staff Accountant, at (202) 551-3733 or in his absence, to Scott Watkinson, Staff Accountant, at (202) 551-3741. 							Sincerely, 							Rufus Decker 							Accounting Branch Chief ?? ?? ?? ?? UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE