April 20, 2005


Mail Stop 03-06

Reed J. Killion
President and Director
Uni-Pixel, Inc.
11940 Jollyville Road, Suite 200N
Austin, Texas 78759

Re:	Uni-Pixel, Inc.
	Amendment No. 1 to Form 10-SB
	Filed April 1, 2005
	File No. 0-49737

Dear Mr. Killion:

      We have the following comments to your filing.  If you
disagree
with our comments, 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.

General
1. Please be advised that we will issue comments on your
confidential
treatment application in a separate letter.
2. We note your response to comment 6.  Please file as an exhibit
the
agreement.  In addition, discuss the "specific milestones" and the
government`s rights to your technology under the agreements.
Also,
clarify the phrase "march-in rights."

      *     *     *

      Please amend your filing within 10 business days, or tell us
when you will provide us with a response.  You may wish to provide
us
with marked copies of the amendment to expedite our review.
Please
furnish a cover letter with your amendment that keys your
responses
to our comments and provides any requested supplemental
information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      You may contact Julie Sherman at (202) 824-5506 or Jay Webb,
Reviewing Accountant, at (202) 942-1812 if you have questions
regarding comments on the financial statements and related
matters.
Please contact Mary Beth Breslin at (202) 942-2914 or me at (202)
942-1927 with any other questions.


      Sincerely,



Thomas A. Jones
Senior Attorney

Reed J. Killion
Uni-Pixel, Inc.
April 20, 2005
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