MICHAEL S. KROME, ESQ.
Attorney-at-Law
8 Teak Court
Lake Grove, New York 11755

Tel.: (631) 737-8381
Fax: (631) 737-8382
email: mskrome@optonline.net

Cheryl A. Krome
Ronald Krome
Legal Assistants

March 8, 2006

John Reynolds, Assistant Director
Office of Emerging Growth Companies
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

REFERENCE: XIOM CORP.
REGISTRATION STATEMENT ON FORM SB-2
AMENDMENT FILED: FEBRUARY 22, 2006
FILE NO. 333-123176

Dear Mr. Reynolds:

Enclosed herewith for filing on behalf of Xiom Corp. (the "Company"),
pursuant to the Securities Exchange Act of 1933, as amended, please find the
Company's Amendment No. 4 to its Registration Statement on Form SB-2 ("Amendment
No. 4"), marked to show the changes to the Company's Registration Statement on
Form SB-2, as filed with the Securities and Exchange Commission on February 22,
2006.

We received your letter of October 11, 2005 and of December 12, 2005,
containing comments prepared by the Staff of the Division of Corporation Finance
of the Securities and Exchange Commissions which pertain to the Registration
Statement, and we hereby submit the following responses to the numbered
comments.

General
- -------
Comment

1. Please provide a more detailed analysis of how this spin-off was effected
in compliance wit our view regarding spin-offs and section 5 of the
Securities Act as reflected in SEC Staff Legal Bulletin No. 4 (CF),
September 16, 1997.

MICHAEL S. KROME, ESQ.

Re: Response Letter to Securities and Exchange Commission Comment letter of
October 11, 2005 for Registration Statement on Form SB-2, Amendment No. 2,
filed September 2, 2005, and December 12, 2005 on Form SB-2, Amendment No.
3, filed December 6, 2005 for Xiom Corp.

March 8, 2006
Page 2 of 17

Response

The transaction with Xiom Corp. (then Panama Industries Ltd.) was intended
to be under and fulfill the requirements of SEC Staff Legal Bulletin No. 4
(CF), September 16, 1997 ("SEC Staff Legal Bulletin"). Specifically, the
SEC Staff Legal Bulletin set out five specific items which when followed
allowed a company subject to the reporting requirements of Section 13 or
15(d) of the Securities Act of 1933, as amended, to "spin-out" a
subsidiary, without filing a registration statement with the Securities
and Exchange Commission. The Staff Bulletin stated five conditions to be
met:

* the parent shareholders do not provide consideration for the
spun-off shares;
* the spin-off is pro-rata to the parent shareholders;
* the parent provides adequate information about the spin-off
and the subsidiary to its shareholders and to the trading
markets;

* the parent has a valid business purpose for the spin-off; and

* if the parent spins-off "restricted securities," it has held
those securities for at least two years.

We believe that the transaction complied with all five items, as follows:

(1) There was no consideration paid for the spun off shares by the
parent company. The shares of the Company were initially issued
without any consideration being paid by any shareholder, and were
issued by the parent company as a stock dividend directly to the
current shareholders.
(2) The spin off was pro-rata to all shareholders then shareholders of
the parent company. Inasmuch as the distribution of the shares to
the original shareholders of the Company was effectuated as a stock
dividend to all holders of shares of the parent company, there was a
pro-rata distribution. No shareholder received, at the time of this
initial distribution, more than the same percentage as any other
shareholder in the spun-off company.
(3) At the time of the spin off the parent company believed that
sufficient information was available to the pubic to comply with the
Staff Legal bulletin, from the reported filings of the parent
company. At the time of the spin off of the company, we believed
that we had complied with the requirement of this provision of SEC
Staff Legal Bulletin No. 4 (CF), September 16, 1997 ("SEC Staff
Legal Bulletin"), in that the parent company (TTI Holdings Corp.
"TTI") was a reporting company under the Securities Act of 1933 and
1934, as amended, and had filed all reports due. Therefore,
management at the time of the distribution believed that sufficient
information was available to the public in accordance with the Staff
Bulletin.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 3 of 17

(4) The purpose of the spin-off was for a valid business purpose. The
business activities of Xiom Corp. (involving metal coatings and
other metal related activities) were outside the sphere of the
proposed acquisition of the parent company. At the time of the
spin-off, in May and June 2001, the parent company was seeking to
enter into a series of transactions to acquire up to eleven
separately owned comprehensive outpatient rehabilitation facilities
("CORF's") that were managed by a Florida based company named Total
Health Care Consulting, Inc ("Total"). The Company was essentially
acquiring the licenses to operate these CORF's with Total providing
the back-office management functions. The acquisition of these
CORF's was to have been executed by the distribution of shares of
TTI to the CORF owners based upon certain financial criteria.
However, on August 24, 2001 the Company terminated the agreements
with the CORF owners and did not consummate the acquisitions upon
being informed that certain representations regarding the financial
condition of the CORF's and Total and other material matters were
found to be not true. Management at the time felt that the
combination of the two separate businesses would have been
diametrically opposed and would have caused integration problems
with the employees, management of the subsidiaries and accounting
issues. The subsidiary that was spun out, then called Panama
Industries, Ltd., and now Xiom Corp. was a viable operating business
and although not profitable, it had the ability to grow on its own.
(5) Finally, the parent company did comply with the fifth and final
requirement in that all of the securities spun off were "restricted
securities" and the parent was not required to register the spin-off
as it had complied with the initial four items. All shares issued in
the spin-out to the shareholders bore a restrictive legend and were
not subject to public sale.

Prospectus Cover Page
- ---------------------

Comment

2. Please limit the outside front cover page to one page as required by Item
501(a) of Regulation S-B.

Response

The outside front cover of the Prospectus has been limited to one page.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 4 of 17

Comment

3. Please disclose the date the offering will end as required by Item
501(a)(9)(iii) of Regulation S-B. You are reminded that Rule 415(a)(2) of
Regulation C limits the offering to an amount that may be offered and sold
within two years.

Response

We have indicated that the offering by the Company will end one year after
the effective date of the prospectus.

Comment

4. We reissue our prior comment 4 and remind you to please limit your
disclosure on the cover page to only the information required by Item 501
of Regulation S-B.

Response
We have removed the disclosure referenced the company's going
concern and moved it to the Summary section.

Comment

5. Please highlight the cross-reference to the risk factors section by
prominent type or some other manner as required by Item 501(a)(5) of
Regulation S-B.

Response

We have highlighted the cross-reference to the risk factors section by
using bold type and capitalizing the sentence.

Comment

6. If applicable, provide the disclosure required by Item 501(A)(10) of
Regulation S-B.

Response

The prospectus contains the information required by Item 501(a)(10) of
Regulation S-B at the top of the page.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 5 of 17

Prospectus Summary, page 4
- --------------------------

Comment

7. We reissue our prior comment 6. Please add disclosure addressing the
company's going concern qualification and its accumulated deficit.

Response

We have added disclosure regarding the company's going concern
qualification.

Comment

8. The disclosure regarding the spin-off is confusing. For example, what do
you mean when you disclose in the second paragraph that "at the time of
the spin-off, TTIH has intended to focus on a specific target merger
candidate involved in a total unrelated business." Revise your disclosure
to clearly indicate the various entities involved in the spin-off, the
business purposes of each, and the manner in which the spin-off was
effected. We may have further comment.

Response

We gave revised the disclosure to make the circumstances about the
spin-off more clear and understandable.

Summary Financial Information, page 5
- -------------------------------------

Comment

9. We note your response to prior comment 8. Please update the information
presented as of September 30, 2004 and 2003 so that the information is
consistent with the revised financial statements included in your filing.
In addition, the information regarding loss per share for the nine months
ended June 30, 2005 should also be revised. Please revise your disclosures
accordingly.

Response

We have updated the summary financial table, as requested, to red as
follows:

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 6 of 17

SUMMARY FINANCIAL INFORMATION

June 30 2005 September 30, 2004 September 30, 2003
------------ ------------------ ------------------

Balance Sheet Data:
Total Assets $ 243,965 $ 190,580 $ 102,739
Total Liabilities $ 91,016 $ 91,416 $ 82,111
Total Stockholders' Equity $ 152,949 $ 99,164 $ 20,628

Statement of Operations:
Revenues $ 58,270 $ 114,479 $ 143,973
Expenses $ 265,398 $ 350,283 $ 239,883
Net Profit (Loss) $ (207,128) $ (235,804) $ ( 95,910)
Basic and Diluted Income (Loss) Per Share (0.04) (0.06) (0.03)
Weighted Average No. Shares Used
In Computing Income (Loss) Per Share 5,676,776 3,970,602 3,632,973

Risk Factors, page 6

Comment

10. We reissue our prior comment. The subheading for the 3rd risk factor
merely reads "Operations and our Technology and Products." Please revise
your subheadings so that they adequately describe the specific risk that
results from the stated fact. To assist you in this regard, we refer you
to "A Plain English Handbook - How to Create Clear SEC Disclosure
Documents," issued by the Officer of Investor Education and Assistance,
which is available on our website at www.sec.gov, and the updated Staff
Legal Bulletin No. 7, dated June 7, 1999.

Response

We have revised our subheading, where possible to make them more
adequately describe the specific risk that results from the stated fact.

Comment

11. We reissue our prior comment 13. Add more risk factor disclosure covering
the industry in which your company operates.

Response

We have added risk factors covering the industry in which our company
operated

Comment

12. We reissue our prior comment 14 because some of the risk factors continue
to be generic. We specifically refer you to the 4th and 6th risk factors.
Please revise your risk factors to so that each discussed a material risk
to your potential shareholders. As a general rule, a risk factor is
probably too generic if it is readily transferable to other offering
documents or describes circumstances or factual situations that are
equally applicable to other similarly situated businesses.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 7 of 17

Response

We have revised the risk factors to make them specific to our Company and
Offering.

Use of Proceeds, page 10
- ------------------------

Comment

13. Revise the disclosure to exclude the proceeds from the exercise of the
warrants when calculating the use of proceeds from the sale of the
company's securities.

Response

We have updated the disclosure to and have excluded the proceeds from the
assumed exercise of the warrants when calculating the Use of Proceeds from
the sale of the Company's securities. We have indicated the changes in
response to Comment 14, below.

Comment

14. Commensurate with Item 504 of Regulation S-B, please disclose the priority
of each contemplated use of proceeds. Because no minimum amount is
required to be sold in your offering, please address the full range of
possible offering proceeds, from sale of a nominal amount to the maximum.
We may have further comment.

Response

We have updated and revised the disclosure commensurate with Item 504 of
Regulation S-B, as follows:

"USE OF PROCEEDS

XIOM Corp. will not receive any proceeds from the sale of the shares by
the Selling Shareholders. XIOM Corp. will receive the proceeds of the
500,000 shares to be sold directly by the Company, from time to time.
There is no guarantee that these additional shares will be sold.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 8 of 17

The following table allocates the proceeds from the sale of shares, at
various levels from a minimum quantity to the maximum quantity, at $3.00
per share and in priority order as to how such proceeds would be utilized.

50,000 200,000 350,000 500,000

Shares Shares Shares Shares
---------- ---------- ---------- ----------

Sales and marketing expenditures $ 100,000 $ 200,000 $ 250,000 $ 300,000
Inventory purchases 50,000 175,000 250,000 350,000
Accounts receivable financing 0 125,000 350,000 500,000
Administrative salaries 0 100,000 200,000 350,000
---------- ---------- ---------- ----------
Total Use of Proceeds $ 150,000 $ 600,000 $1,050,000 $1,500,000
========== ========== ========== ==========

Determination of Offering Price, page 10
- ----------------------------------------

Comment

15. Reconcile he information contained here with that contained on page 5
where you indicate the price of the shares was arbitrarily determined..

Response

We have removed the reference on Page 5.

Management's Discussion and Analysis, page 11
- ---------------------------------------------

Comment

16. Expand the disclosure about the "new expected distributors" in Washington
State, Texas, Louisiana and Minneapolis.

Response

We have a signed agreement with a distributor in Texas. We are attaching a
copy of the signed Distribution Agreement as a Material Agreement to the
Registration Statement. We also have a distributor in Huntington, New York
and Saskatchewan, Canada, and are including those Agreements as an
Exhibits, as well. We have expanded the disclosure to include the material
terms and conditions of the Agreements. We have no other distributors and
have removed the references to other locations.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 9 of 17

Comment

17. Discloser indicated that the first road show is scheduled for mid
September in Boston. Disclose the results of this road show.

Response

We did not conduct the road show as planned. The road show was cancelled
due to the company not having the wherewithal to pay for it. Accordingly,
we have removed all reference to the road show in the disclosure statement

Comment

18. Please identify the "well known testing agency" with whom you are
collaborating.

Response

We have included the name of the "well know testing agency" which is "KTA
Tater, located in Pittsburgh, Pennsylvania.

Comment

19. We reissue our prior comment 22 because your revised disclosure is only
partially responsive to our comment. Please provide a potential investor
with a comprehensive disclosure in the direction in which you plan to take
your company in the next twelve months. You should focus your discussion
in monthly or quarterly increments and discuss the steps necessary for,
the costs associated with, and projected timeframes for achieving
sustained first revenues. Currently, you do not identify any specific
milestones nor do you discuss the ways in which you intend to generate
sustained revenues. We may have additional comment after reviewing your
revised disclosure.

Response

We have updated the disclosure as required.

Business of the Company, page 13
- --------------------------------

Comment

20. We reissue our prior comment 30 [should read 20]. Please review the
disclosure requirements of Item 101 of Regulation S-B and revise your
disclosure in accordance with the information that you are required to
present. Your current description of your business continues to be vague
and does not provide a prospective investor with the information he or she
needs to clearly evaluate your product and the ability of the company to
survive in the short and long term. We note that you have removed the
disclosure relating to what appears to be your sole product, the XIOM 1000
polymer multicoat spray system. Please explain why you have done so. In
the alternative, replace your disclosure and provide specific information
about its production/manufacturing status and key attributes of the
product and or service. We may have further comment after reviewing your
revised disclosure.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 10 of 17

Response

We have updated the disclosure to comply with Item 101 of Regulation S-B.

Comment

21. Some of the disclosure in the third paragraph on page 13 may be considered
promotional. Please revise to remove all statements that appear
promotional in nature.

Response

We have removed what we consider to be promotional language from the
paragraph.

Comment

22. Disclosure on page 13 indicates that you have applied for "viable
patents." Please provide the disclosure required by Item 101(b)(7) of
Regulation S-B.

Response

We have included the following descriptions regarding the patents filed by
the Company"

"The first patent is an equipment patent that covers the nozzle
configuration and the propane, oxygen and air mixture configuration,
in the gun, with a process description also included.

The second patent covers the powder-feeder apparatus delivery
mechanism, which feeds the nozzle configuration contained in the
first patent.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 11 of 17

The third patent covers the material feed-stock (powder), which is
used by the devices, which is fed through the nozzle configuration
and the powder-feeding configuration from the first two patents
described.

We have also filed international patents to cover the three items
listed."

Comment

23. We reissue our prior comment 27. Expand your disclosure relating to you
distributorships. Please identify your distributors and discuss their role
in the company's operations. To the extent you maintain agreements with
distributors, please disclose the material terms, financial and otherwise,
of the agreements and file the agreements a material exhibits.

Response

We have updated the disclosure to remove any discussion of
distributorships.

Management, page 15
- -------------------

Comment

24. We note your supplemental response to our prior comment 31. Please
disclose in the prospectus the fact that Messrs. Mazzone and Gardega are
your promoters.

Response

We have indicated in the prospectus, in the Management section that both
Mr. Mazzone and Mr. Gardega are to be promoters of the Company. It has
been indicated in the listing of positions with the Company and at the
conclusion fo the biographies.

Dilution, page 18
- -----------------

Comment

25. We note your response to prior comment 38. Please update the information
as of the most recent balance sheet date presented in the registration
statement.

Response

The information has been updated as of the most recent balance sheet date,
as follows:

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 12 of 17

DILUTION

Our net tangible book value as of June 30, 2005 was $152,949, or $0.03 per share
of common stock. Net tangible book value per share represents tangible assets,
less liabilities, divided by the number of shares of common stock issued and
outstanding. The following table illustrates the dilution to purchasers of
common stock in this offering at various arbitrarily determined sales levels, at
an assumed public offering price of $ 3 per share. At the sales levels
indicated, our pro forma net tangible book value at June 30, 2005 would have
been $752,949, $1,052,949, $1,352,949, or $1,652,949 respectively. This
represents an immediate dilution of $2.87, $2.82, $2.78 or $2.73 per share,
respectively, to new investors.

Number of Shares of Common Stock Sold in the Offering(1)
200,000 300,000 400,000 500,000
Shares Shares Shares Shares

Public offering price per share 3.00 3.00 3.00 3.00
----------------------------------------

Net tangible book value before the offering 0.03 0.03 0.03 0.03
Increase in net tangible book value
attributable to new investors 0.10 0.15 0.19 0.24
----------------------------------------

Pro forma net tangible book value per share
after the offering 0.13 0.18 0.22 0.27
----------------------------------------

Dilution per share to new public investors 2.87 2.82 2.78 2.73

(1) The above dilution calculations do not give effect to the outstanding
warrants to purchase up to 157,062 shares of common stock at $.75 per share.

Business of the Company - Principal Products and Services, page 18
- ------------------------------------------------------------------

Comment

26. We note your disclosure that indicated that you currently do business and
are expanding your business into Africa, Mexico and Columbia. Provide
disclosure here or elsewhere as appropriate, to discuss the issues faced
by the company in operating in foreign markets, identify any additional
costs of doing business internationally, and consider adding a risk factor
to discuss this fact.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 13 of 17

Response

The reference to Africa, Mexico and Columbia should have read as selling
to businesses in foreign countries. The Company has no distributorships,
nor any plans for distributorships overseas or plans to set up any
operations of any kind. The disclosure has been revised to indicate that
the Company has made sales to other countries, but does not conduct any
business there.

Offering by Selling Shareholders, page 19
- -----------------------------------------

Comment

27. Disclosure in the first paragraph indicates that the selling shareholders
will sell at the fixed price of $3.00 for the duration of the company's
primary offering. Please clarify. Disclosure elsewhere indicated that the
selling shareholders will sell at $3.00 until the shares are quoted on the
Over the Counter Bulletin Board.

Response

We have updated the disclosure to be consistent with the reference to the
selling shareholders selling their shares at $3.00 until the shares are
quoted on the Over the Counter Bulletin Board, if ever.

Plan of Distribution, page 21
- -----------------------------

Comment

28. Please disclose your supplemental response to our prior comment 42.

Response

We have inserted our supplemental response to prior comment 42, as
requested.

Where you can find more information, page 24
- --------------------------------------------

Comment

29. Please update the Commission's address.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 14 of 17

Response

We have updated the Commissions address

Audit Report, page F-2
- ----------------------

Comment

30. We note your response to prior comment 45. Please revise the report to
include a conformed signature at the bottom of the report, directly above
the city and state where the report was issued. Typically, the conformed
signature would appear in the form of: "/s/[Registered Accounting Firm]"

Response

We have indicated and included a conformed signature on the Audit Report

Note 4 - Patents Pending, page F-9
- ----------------------------------

Comment
31. We note your response to prior comment 51. Pleas revise the
financial statements to include the disclosures required by
paragraphs 44-45 of FAS 142.

Response
We have revised the financial statements to include the
disclosures required by paragraphs 44-45 of FAS 142.

Note 13 - Related Party Transactions, page F-10
- -----------------------------------------------

Comment
32. We note your responses to prior comment 46. Please disclose the
value of the contributed services for each period in the footnotes
to the financial statements.

Response
We have disclosed the value of the contributed services for each
period presented in the footnotes to the financial statements.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 15 of 17

Comment

33. Please disclose on the face of the financial statements that they have
been restated, disclose in a note the nature and amount of the restatement
as required by paragraph 37 of APB 20, and direct your independent
accountant to refer to the restatement of the annual financial statements
in its report and dual-date or redate the report.

Response

Paragraph 37 of APB 20 refers to required disclosures related to the
correction of an error as a prior period adjustment in previously issued
financial statements. The financial statements included in the filing have
not been previously issued to any third parties. Such issuance was subject
to the current filing becoming effective. As such, the financial
statements included in the filing have not been restated, but have been
corrected as a result of the requested changes and the accountant's report
has been appropriately redated.

Note 3 - Stock Option Grants, page F-15
- ---------------------------------------

Comment

34. We note your response to prior comment 58. Based on your revised
disclosure, it appears that no compensation expense was recognized for the
option grant to the consultant. Note that under FAS 123, options granted
non-employees must be recorded at fair value, with limited exception for
non-employee directors meeting all of the conditions of paragraph 8 of FIN
44. Please revise the financial statements as appropriate to include
compensation expense relating to the non-employee grant, and disclose the
fair value of the grant under FAS123, along with the major assumptions
used to value the award. Also, please revise your disclosures under
Executive Compensation on page 16 to discuss the stock option grants to
the officers

Response

We have update Note 3 and adjusted the June 30, 2005 interim financials as
requested. We determined the value of the non-employee option on the date
of the grant to be "minimal", as defined in paragraph 20 of FAS 123.
Additionally, because the Company is a "non-public entity", the expected
volatility of its stock over the expected life of the option was
appropriately not considered. We have also revised our disclosure under
"Executive Compensation" as requested.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 16 of 17

"EXECUTIVE COMPENSATION

The officers of XIOM Corp. currently have no formal, or informal,
compensation arrangements. They are reimbursed only for documented
out-of-pocket petty cash expenses and by issuing shares, or granting
of options, for services. On March 1, 2005, XIOM granted two options
to purchase a total of 600,000 shares of restricted common stock at
a price of $.75 per share, which approximates the fair market value
on the date of the grant. The two operating officers, who are also
shareholders, each received an option to purchase 300,000 restricted
common shares.

All directors hold office until the next annual meeting of
stockholders and the election and qualification of their successors.
Executive officers are elected annually by the Board of Directors to
hold office until the annual meeting of shareholders and until their
successors are chosen and qualified."

Comments of December 12, 2005

Financial Statements

Comment

1. We note that the financial statements included in the registration
statement do not meet the updating requirements of Item 310(g) of
Regulation S-B. Since you do not meet all of the conditions specified in
Item 310(g)(2) of Regulation S-B, audited financial statements for the
year ended September 30, 2005 were required to be filed in the current
amendment. Please revise the filing accordingly.

Response

We have updated the financial information in the registration statement to
comply with Item 310(g) of Regulation S-B.

Comment

2. We note that the filed consent refers to the audit report dated March 25,
2005, which is inconsistent with the sate of the audit report included in
the registration statement. Please ensure that an updated and currently
dated consent is included in your next amendment.

MICHAEL S. KROME, ESQ.

March 8, 2006
Page 17 of 17

Response

We have filed and updated and currently dated consent related to the Audit
report.

Comment

3. We note your supplemental response regarding the use of zero volatility
assumption to value stock options granted to non-employees. Please note
that the use of the minimum value method described in paragraph 20 of FAS
123 is only applicable to stock-based compensation awards made to
employees. As discussed in footnote (1) to EITF 96.18, the minimum value
method is not an acceptable method for determining the fair market value
of non-employee awards by nonpublic companies. Please revise the financial
statements accordingly.

Response

We have updated the financial statements and footnotes accordingly.

This letter responds to all comments contained in your letters of October
11, 2005 and December 12, 2005. We are requesting that your office expedite the
review of this amendment as much as possible.

If you have any questions, please do not hesitate to call me at
631-737-8381.

Very truly yours,

Michael S. Krome

cc: Mr. Andrew Mazzone,
President, Xiom, Inc.