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                             October 27, 2020

       Jessica L. Thomas
       Chief Financial Officer
       Mechanical Technology, Incorporated
       325 Washington Avenue Extension
       Albany, NY 12205

                                                        Re: Mechanical
Technology, Incorporated
                                                            Registration
Statement on Form 10
                                                            Filed September 30,
2020
                                                            File No. 000-06890

       Dear Ms. Thomas:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

            After reviewing your response and any amendment you may file in
response to these
       comments, we may have additional comments.

       Form 10-12G filed September 30, 2020

       Financial Statements for the Three and Six Months Ended June 30, 2020
       Condensed Consolidated Statements of Operations (Unaudited), page F-3

   1.                                                   We see that in the
three months ended June 30, 2020 you recognized $50,000 of
                                                        cryptocurrency revenue
with no related cost of sales. Please describe your basis under
                                                        ASC 606 for recognizing
revenue from the cryptocurrency transactions and tell us how
                                                        you are accounting for
and reporting the related costs of realizing this revenue.
       Condensed Consolidated Statements of Changes in Equity, page F-4

   2.                                                   Please revise to
provide year-to-date periods with subtotals for the comparative prior
                                                        interim period, i.e. a
reconciliation covering each period for which an income statement is
                                                        presented. Refer to
Rule 8-03(a)(5) of Regulation S-X.
 Jessica L. Thomas
Mechanical Technology, Incorporated
October 27, 2020
Page 2
Note 1. Nature of Operations, page F-6

3.       We see from your disclosure that on May 21, 2020 EcoChain closed its
acquisition of the
         intellectual property of Giga Watt, Inc. and certain other property
and rights of GigaWatt
         associated with GigaWatt's operation of a crypto-mining operation
located in Washington
         State and those acquired assets will form the cornerstone of your new
cryptocurrency
         mining operation. Please revise to disclose the total purchase price
and clearly describe
         your accounting for the acquisition under ASC 805.
Note 9. Related Party Transactions
Soluna Transactions, page F-11

4.       We note that the Operating and Management Agreement requires, among
other things,
         that Soluna provide developmental and operational services, as
directed by EcoChain,
         with respect to the cryptocurrency mining facility in exchange for
EcoChain's payment to
         Soluna of a one-time management fee of $65,000 and profit-based
success payments in
         the event EcoChain achieves explicit profitability thresholds. Please
revise your disclosure
         to provide the terms and amounts of these profit based success
payments.
Financial Statements for the Years Ended December 31, 2019 and 2018
Independent Auditors Report, page F-16

5.       We note that the opinion from Wojeski & Company CPAs, P.C. references
auditing
         standards generally accepted in the United States of America and does
not conform to the
         format required by PCAOB AS 3101. Please amend the filing to include
financial
         statements that are audited in accordance with the standards of the
Public Company
         Accounting Oversight Board and a report of your independent auditors
that full complies
         with the guidance in PCAOB AS 3101.06 through .10 and Article 2 of
Regulation S-X.
         This includes the title,    Report of Independent Registered Public
Accounting Firm   , the
         opinion included as part of the first section of the report,
appropriate references to being
         registered with the PCAOB and its standards and a statement containing
the year they
         began serving consecutively as auditor. Refer to PCAOB Release No.
2017-001.
Note 2. Accounting Policies
Revenue Recognition, Accounts Receivable and Allowance for Doubtful Accounts,
page F-23

6.     Please expand your accounting policy to address how you determine the
transaction price
       for your major contract types, including your assessment of variable
consideration and the
       application of constraint. Explain more fully the nature of the products
and services
       transferred, and provide us your analysis supporting your conclusion
that your product and
FirstName LastNameJessica L. Thomas
       services revenues can be combined. Tell us why disaggregated disclosure
by nature of
Comapany    NameMechanical
       activity,              Technology,
                 region, product            Incorporated
                                 type or other relevant category is not
required under ASC 606-10-
October50-5
         27, and
             202055-89
                   Pagethrough
                         2       55-91.
FirstName LastName
 Jessica L. Thomas
FirstName
MechanicalLastNameJessica  L. Thomas
            Technology, Incorporated
Comapany
October  27,NameMechanical
             2020           Technology, Incorporated
October
Page  3 27, 2020 Page 3
FirstName LastName
Accounting Updates Not Yet Effective, page F-26

7.       Please revise to disclose the expected effect of the adoption of ASU
2018-18,
         Collaborative Arrangements on your financial statements, or tell us
why such disclosure is
         not required.
Note 11. Stock Based Compensation, page F-32

8.       Please revise to remove the impact of stock-based compensation expense
on basic and
         diluted EPS as it represents a non-GAAP measure that is prohibited
from the footnotes to
         your financial statements under Item 10(e)(1)(ii)(C) of Regulation
S-K.
General

9.       Please be advised that your registration statement will become
effective
         automatically sixty days after filing, pursuant to Section 12(g)(1) of
the Securities
         Exchange Act of 1934. Upon effectiveness, you will become subject to
the reporting
         requirements of the Securities Exchange Act of 1934, even if we have
not cleared your
         comments. If you do not wish to incur those obligations until all of
the following issues
         are resolved, you may wish to consider withdrawing your registration
statement and
         submitting a new registration statement when you are in a position to
revise your
         document.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Julie Sherman at 202-551-3640 or Kevin Kuhar at
202-551-3662 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jeffrey Gabor at 202-551-2544 or Joe McCann at 202-551-6262 with any
other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Life
Sciences
cc:      Penny Somer-Greif, Esq.