August 18, 2008

Brian Cascio
Accounting Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
Washington, DC 20549

Re: CVD Equipment Corporation
      Form 10-KSB for the Year Ended December 31, 2007
      File No. 001-16525

Dear Mr. Cascio

      This letter is in response to the letter (the “SEC Letter”) dated July 17, 2008 from the Securities and Exchange Commission concerning the above referenced filing. 

     Comment.  It does not appear that your Management has performed its assessment of internal controls over financial reporting as of December 31, 2007.  Since you were required to file or filed an annual report for the prior fiscal year, it appears you are required to report on your management’s assessment of internal control over financial reporting.

     Answer:  The Registrant is filing simultaneously herewith an amendment to its Form 10-KSB for the year ended December 31, 2007 to include the disclosures required under Part II, Item 8A(T), Controls and Procedures relating to its assessment of internal controls over financial reporting as of December 31, 2007. 

     2.  Comment.  Your Principal Executive Officer and Principal Financial Officer certifications under Item 601(b)(31) of Regulation S-B.  Please revise these certifications to include the introductory language of paragraph 4 and the language of paragraph 4(b) of Item 601(b)(31) of Regulation S-B.

     Answer:  The Registrant is filing simultaneously herewith an amendment to its Form 10-KSB for the year ended December 31, 2007 to include revised and re-executed Principal Executive Officer and Principal Financial Officer certifications filed under Exhibits 31.1 and 31.2 to include the introductory language of paragraph 4 and the language of paragraph 4(b) of Item 601(b)(31) of Regulation S-B. 

The Company acknowledges that:

      (1)  The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

      (2)  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

      (3)  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.

Very truly yours,

/s/ Adam P. Silvers

ADAM P. SILVERS

For the Firm