Mail Stop 0405
June 8, 2005

Mr. Floyd H. Panning
Chief Executive Officer
Electropure, Inc.
23456 South Pointe Drive
Laguna Hills, California 92653

      Re:	Electropure, Inc.
      	Preliminary Information Statement on Schedule 14C
      Filed May 16, 2005
      File No. 0-16416

Dear Mr. Panning:

      We have limited our review of your filing to those issues we
have addressed in our 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 on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Information Statement, page 3

1. We note that holders of the majority of the votes of your stock
approved the sale of substantially all of the assets of
Electropure
EDI, Inc. to Snowpure, LLC, and the subsequent dissolution and
termination of the corporate existence of the EDI subsidiary.
Because
the proposed transaction involves the sale of a "substantial part
of
assets" within the meaning of paragraph (a)(4) of Item 14 of
Schedule
14A, the information statement must include all of the information
specified by Item 14, including a summary term sheet.  In
addition, in
the context of a material disposition of assets, the historical
financial statements of the seller, in addition to pro forma
financial
statements meeting the requirements of Regulation S-X, are
typically
necessary to inform shareholders of the scope of the transaction
and
its effect on the company.  Please amend your information
statement to
provide all of the information required by Item 14 or tell us why
you
are not required to include such information.

Additional Information, page 15

2. We note that the company has failed to file its required
periodic
reports.  Please file all required reports or advise us as to when
you
will file such reports.

Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with a marked copy 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 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.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing
includes all information required under the Securities Act of 1934
and
that they have provided all information investors require for an
informed investment decision.  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 the filing;

* 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 connection with our review of your
filing or
in response to our comments on your filing.





      Please contact Jason Wynn at (202) 551-3756 or the
undersigned
at (202) 551-3685 with any questions.  Direct all correspondence
to
the following ZIP code:  20549-0405.

							Sincerely,



							Tangela S. Richter
							Branch Chief

cc:	J. Wynn

      via facsimile

      James J. Scheinkman
      Snell & Wilmer
            (949) 955-2507

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Mr. Floyd H. Panning
Electropure, Inc.
June 8, 2005
page 1


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE