November 7, 2005
Angela D. Toppi, Chief Financial Officer
Trans-Lux Corporation
110 Richards Avenue
Norwalk, CT 06856-5090

RE:	Trans-Lux Corporation   File No. 1-2257
	Form 10-K for the fiscal year ended December 31, 2004
	Filed March 31, 2005

Dear Ms. Toppi:

	We have reviewed your response letter dated October 7, 2005
and
have the following additional comments.

Prior Comment 4 - Business Segment Data, page 26
1. We note you believe that foreign revenues are not material to
an
understanding of your financial statements. However, it appears
that
the foreign operations have a significantly higher profit margin
relative to the domestic operations. Taking information from Note
7
on page 22, we note that the 2004 foreign income tax expense of
$306k, considered with the foreign effective income tax rate of
42.8%, infer a foreign pre-tax income of approximately $715k.
Given
that the 2004 consolidated earnings before taxes was $443k, it
appears that foreign operations are significantly more profitable
than your domestic operations. Please provide an MD&A disclosure
to
clarify for readers whether the foreign operations have a
materially
different profit margin than the domestic operations.

Prior comments 5 and 6 - MetroLux Theaters Financial Statements,
page
28
2. We have read your response to prior comments five and six.  We
are
unable to conclude that the omission of required financial
statements
and audit reports is consistent with the protection of investors.
Please amend your filing to include the 2002 financial statements
as
required by Article 3-09 of Regulation S-X, along with the audit
report for MetroLux Theatres required by Article 2-05 of
Regulation
S-X.  In addition, please include the audit opinion for MetroLux
for
the 2003 fiscal year.

      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 marked copies of
the amendment to expedite our review.  Please furnish a letter
that
keys your responses to our comments and provides any requested


supplemental information.  Detailed response letters greatly
facilitate our review.  Please file your response letter on EDGAR.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.

	You may contact Tracey McKoy, Staff Accountant, at (202) 551-
3772 or in her absence, Al Pavot at (202) 551-3738, or me at (202)
551-3255 if you have questions regarding comments on the financial
statements and related matters.


Sincerely,




								Nili Shah,
Accounting Branch Chief
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Ms. Toppi
Trans-Lux Corporation
November 7, 2005
Page 1



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

         DIVISION OF
CORPORATION FINANCE