Mail Stop 7010
								January 26, 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 filing 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

Controls and Procedures, page 14

1.		Revise future filings to exclude the qualifying language
"other than as described below" in your disclosure of changes in
internal control over financial reporting.  Also confirm to us, if
correct, that there were material changes in your internal control
over financial reporting during the quarter ended June 30, 2005.



Note 1 - Summary of significant accounting policies, page F-6

2.		We note the additional information you submitted on
revenue
recognition.  Please tell us the general nature of the terms and
conditions included in the purchase orders, and how and when you
recognize revenue as such terms and conditions are met.  Tell us
if
any purchase orders require customer approval.

3.		Tell us the percentage of total 2004 revenues that use
the
percentage of completion method.  Also tell us the terms of this
agreement and how you determine the percentage of completion
method
is appropriate.

      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.
January 26, 2006
Page 1


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

         DIVISION OF
CORPORATION FINANCE