Mail Stop 7010
								March 28, 2006



Cari L. Jaroslawsky
Chief Financial Officer
Servotronics, Inc.
1110 Maple Street
Elma, New York 14059-0300

      Re:	Servotronics, Inc.
      Form 10-KSB for Fiscal Year Ended December 31, 2004
		File No. 1-7109

Dear Ms. Jaroslawsky:

      We have reviewed your responses and have the following
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.

	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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB for Fiscal Year Ended December 31, 2004

Prior Comment 2

1.		In your response you state that you recognize revenue
when
units are shipped based on the designated FOB point.  It appears
to
us that you should revise your revenue recognition policy in
future
filings to clarify that fact by deleting the current reference to
"as
terms and conditions of purchase orders are met" since it does not
appear to be accurate.


Prior comment 3

2.		It remains unclear to us why you believe your use of
percentage of completion accounting is appropriate based on the
provisions of SOP 81-1.  Please tell us the specific terms and
provisions of this contract and provide support for your
accounting.
It is unclear to us why the criteria you identified in your
response,
impact your revenue recognition policy.  In addition, please help
us
understand the impact on your financial statements of recognizing
revenue under the percentage of completion method of accounting
rather than as units were shipped for FY 2003, FY 2004 and each
quarterly period in FY 2005, including the impact on revenue and
net
income.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
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.

      You may contact Bret Johnson at (202) 551-3753, Anne
McConnell
at (202) 551-3709, or me at (202) 551-3768 if you have questions
regarding our comments.


Sincerely,



John Cash
Accounting Branch Chief

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Ms. Jaroslawsky
Servotronics, Inc.
March 28, 2006
Page 1


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

         DIVISION OF
CORPORATION FINANCE