VIA FACSIMILE 202.772.9369

March 2, 2006

John Cash
Accounting Branch Chief
Securities and Exchange Commission
MAIL STOP 7010
450 Fifth Street, N.W.
Washington, D.C. 20549-7010


Dear Mr. Cash:

This  letter is being filed to respond to comments  made by the  Securities  and
Exchange  Commission staff (the "Staff") in its comment letter dated January 26,
2006. We have  transcribed  the Staff's  comments  below and each of the Staff's
comments is followed by the Company's responses.

FORM 10-KSB FOR FISCAL YEAR ENDED DECEMBER 31, 2004.
- ----------------------------------------------------

CONTROLS AND PROCEDURES, PAGE 14
- --------------------------------

COMMENT 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.

RESPONSE:         We will  revise  future  filings  to  exclude  the  qualifying
                  language in our disclosure of changes in internal control over
                  financial  reporting.  During the quarter ended June 30, 2005,
                  we did not make  material  changes in  internal  control  over
                  financial reporting.



NOTE 1- SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES, PAGE F-6
- ------------------------------------------------------------

COMMENT 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.


John Cash                                                            Page 2 of 2
Accounting Branch Chief
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549





RESPONSE:         Customer  generated and customer  approved purchase orders are
                  reviewed  and  subject  to   acceptance  by  the  Company  and
                  generally  include  specific terms relative to quantity,  item
                  description,  specifications,  price, customer  responsibility
                  for  in-process  costs,  delivery  schedule,  shipping  point,
                  payment and other  standard  terms and  conditions of purchase
                  and may  provide for  progress  payments  based on  in-process
                  costs as they are incurred.  Revenues are  recognized as units
                  are shipped and at the  designated FOB point  consistent  with
                  the  transfer of title and as per our response to your Comment
                  Three (3) as follows.

COMMENT 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.

RESPONSE:         Revenue under the  percentage of completion  method  accounted
                  for  approximately  7% of  revenues  for the fiscal year ended
                  December  31,  2004.  However,  please note that the amount of
                  2004 revenues  recognized  under the  percentage of completion
                  method are not materially  different than if the percentage of
                  completion  revenues were  recognized  under the units shipped
                  method.  Currently,  the Company  expects  revenues  under the
                  percentage of completion method to be an immaterial percentage
                  of total  revenues.  The use of the  percentage  of completion
                  method is  expected  to be  complete  during 2006 and no other
                  contract  will  then be using  the  percentage  of  completion
                  method to recognize  revenues.  The Company uses percentage of
                  completion  method to recognize revenue on contracts where the
                  following  criteria  are met:  (i) the goods to be sold extend
                  over  several  accounting  periods,   (ii)  the  shipment  and
                  delivery  schedules may not properly  match sales with related
                  expenses if recognized  under the units complete  method (iii)
                  expected cash inflows are determinable, (iv) the total cost of
                  the project can be reasonably estimated, (v) the cost incurred
                  is known.  The terms of the agreement met the above parameters
                  as the stated  delivery  dates  extended  multiple  accounting
                  periods  at  stated  prices  and  total  contract  costs  were
                  reasonably estimated based on historical records. As such, the
                  percentage of completion  method was appropriately applied and
                  most accurately addresses the realization  principle that sets
                  forth the criteria for appropriate revenue recognition.

                                          Sincerely,



                                          /s/ Cari L. Jaroslawsky
                                          --------------------------------------
                                          Cari L. Jaroslawsky, CPA
                                          CFO and Treasurer