Intermagnetics
IGC----------------------
      General Corporation

                                                     November 19, 2004

Mr. John Hartz
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
Washington, DC  20549-0510


                    FORM 10-K FOR THE YEAR ENDED MAY 30, 2004
                    -----------------------------------------

Note A - Significant accounting Policies - Revenue Recognition
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     1.   You indicate in your response to prior comment number 12 that you
          recognize revenue under research and development contracts with the US
          Government as well as other customers.
          o    In future filings, revise your income statement captions "net
               sales" and "costs of products sold" to "net revenues" and "costs
               of revenues" or some other similarly worded captions to clarify
               that these line items reflect revenues and costs related to both
               products and services.
               o    RESPONSE;
               IN FUTURE FILINGS WE WILL REVISE OUR CAPTIONS FOR THE ABOVE THE
               ITEMS TO "NET REVENUES" AND "COSTS OF REVENUES".

          o    Revise your revenue recognition policy to better differentiate
               between products sales and revenue earned under research and
               development agreements. Your response indicates that all of your
               research and development contracts are accounted for in
               accordance with SOP 81-1. Your current accounting policies appear
               to differentiate between revenues recognized under research and
               development contracts with the federal government and other
               customers.
               o    RESPONSE;
               IN FUTURE FILINGS WE WILL REVISE OUR DISCLOSURE TO BETTER
               DIFFERENTIATE BETWEEN PRODUCT SALES AND REVENUE EARNED AS A
               RESULT OF FUNDED RESEARCH AND DEVELOPMENT PROJECTS. ADDITIONALLY,
               WE WILL NO LONGER MAKE ANY DISTINCTION BETWEEN REVENUES ACCOUNTED
               FOR IN ACCORDANCE WITH SOP 81-1.




          o    You indicate under your product research and development
               accounting policy that these costs are included in operating
               expenses. Based on your response letter and your disclosures on
               page 19 (which presents product research and development costs
               for 2004, 2003 and 2002 that are in excess of the amounts
               reflected under the caption "product research and development" on
               your consolidated income statements), we assume that you have
               reflected product research and development expenses incurred
               under research and development contracts within cost of products
               sold. Please revise your future disclosures to clarify.
               o    RESPONSE;
               YOUR ASSUMPTION IS CORRECT. WE DO REPORT EXPENSES INCURRED UNDER
               RESEARCH AND DEVELOPMENT CONTRACTS WITHIN COST OF PRODUCTS SOLD.
               WE WILL REVISE OUR FUTURE DISCLOSURES TO CLARIFY WHERE THESE
               EXPENSES ARE RECORDED.

     FORM 10-Q FOR THE QUARTER ENDED AUGUST 29, 2004 AND FORM 8-K/A#1 DATED
     ----------------------------------------------------------------------
                               SEPTEMBER 29, 2004
                               ------------------

     2.   We note your response to our prior comments 17 and 18 that you will
          amend your Form 10-Q for the quarter ended August 29, 2004 and Form
          8-K/A#1 dated September 29, 2004. Please file these reports as soon as
          possible.
               o    RESPONSE;
               WE ARE IN THE PROCESS OF GATHERING AND COMPLETING THE REQUIRED
               INFORMATION AND WILL REVISE THE ABOVE REPORTS AS SOON AS
               POSSIBLE.

General
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     3.   As requested in our comment letter dated October 14, 2004, please
          provide the three acknowledgements in your next response to us. These
          are:
          o    The Company is responsible for the adequacy and accuracy of the
               disclosure in their filings;
          o    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



          o    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.
               o    RESPONSE;

          WE ACKNOWLEDGE:

          o    THE COMPANY IS RESPONSIBLE FOR THE ADEQUACY AND ACCURACY OF THE
               DISCLOSURE IN THEIR FILINGS;
          o    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
          o    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.



          /s/ Glenn H. Epstein
          -------------------------------------------------
          GLENN H. EPSTEIN
          CHIEF EXECUTIVE OFFICER AND CHAIRMAN OF THE BOARD
          NOVEMBER 19, 2004



          /s/ Michael K. Burke
          -------------------------------------------------
          MICHAEL K. BURKE
          CHIEF FINANCIAL OFFICER AND EXECUTIVE VICE PRESIDENT
          NOVEMBER 19, 2004