Mail Stop 7010

April 6, 2006

via U.S. mail and facsimile

William E. Nielsen
Chief Executive Officer
Waste Technology Corp.
5400 Rio Grande Avenue
Jacksonville, Florida, 32554


	RE:	Waste Technology Corp.
		Form 10-KSB for the Fiscal Year Ended October 31, 2005
		Filed January 27, 2006
		File No. 0-14443

Dear Mr. Nielsen:

      We have reviewed the above referenced filing and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and do not intend to
expand our review to other portions of your documents.  Where
indicated, we think you should revise your disclosures in future
filings 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 supplemental 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-KSB for the Fiscal Year Ended October 31, 2005

Management`s Discussion and Analysis, page 8
1. We note your current disclosure only discusses the factors that
led to changes in sales and net income year over year.  In future
filings, please expand your MD&A to discuss the factors that
contributed to any material changes in gross margins and operating
expenses.  In this regard we note that your margins have
significantly fluctuated over the past several years.
Furthermore,
we note that that you previously agreed to provide this disclosure
in
your letter dated April 9, 2003.

Note I - Revenue Recognition, page F-7
2. We note from your disclosure on page 5 that you provide repair
services.  Please tell us and include in future filings your
revenue
recognition policy for repair services.  We remind you that you
previously agreed to provide this disclosure in your letter to us
dated April 9, 2003.

Note 7 - Commitments and Contingencies, page F-10

3. In your disclosure under legal proceedings on page 7, you
disclose
that an estimate of the potential range of loss cannot be made
relating to the legal action filed in March 2005.  Please tell us
how
you made this determination given that you know the plaintiffs are
seeking damages of $820,000 through March 21, 2005 and an
additional
$91,550 per month from that day forward.

If you should conclude the amount of loss or a range of losses can
be
reasonably estimated, tell us how you considered paragraph 8 of
SFAS
5.

Furthermore, in future filings, please provide the required
disclosures of paragraphs 9 and 10 of SFAS 5 as part of your
audited
footnote for commitments and contingencies.

*    *    *    *

      As appropriate, 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 supplemental information.  Detailed
response
letters greatly facilitate our review.  Please file your response
letter on EDGAR.  Please understand that we may have additional
comments after reviewing responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 their filings;
* staff comments or changes to disclosure in response to staff
comments 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 Tracey McKoy, Staff Accountant, at (202) 551-
3772 or, in her absence, Melissa Rocha at (202) 551-3854, or me at
(202) 551-3255 if you have questions regarding comments on the
financial statements and related matters.



Sincerely,



								Nili Shah
								Accounting Branch Chief



Mr. Nielsen
Waste Technology Corp.
April 6, 2006
Page 3



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

         DIVISION OF
CORPORATION FINANCE