October 10, 2006

Mail Stop 7010

Via U.S. mail and facsimile

Mr. Reggie Cook, Chief Financial Officer
Aduddell Industries, Inc.
1601 N.W. Expressway
Oklahoma City, Oklahoma  73118

Re:	Aduddell Industries, Inc.
	Registration Statement on Form S-3, as amended
      Filed on September 21, 2006, and amended on September 26,
2006
	File No. 333-137487
	Annual Report on Form 10-K, as amended
      For the Fiscal Year Ended December 31, 2005
	Filed on March 15, 2006, and amended on April 19, 2006
	File No.:  0-24684

Dear Mr. Cook:

	We have limited our review of your filing to those issues we
have
addressed in our comments.  Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We
look forward to working with you in these respects.  We welcome
any
questions you may have about our comments or any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.

Eligibility Requirements for Use of Form S-3

1. Please advise us supplementally of the transaction requirements
the
company relied upon in determining its eligibility for use of the
Form
S-3 for the registration of the security offering.  Please refer
to
General Instructions I.B. of  the Form S-3.

Legal Matters, page 3
2. In an amendment to the registration statement on Form S-3,
please
file an updated legality opinion by McAfee & Taft as Exhibit 5.

Signatures, page 7
3. The registration statement should also be signed by the
company`s
controller or principal accounting officer whose title should be
included on the signature page.

Annual Report on Form 10-K, as amended
4. The staff`s limited review of the pending registration
statement on
Form S-3 includes our review of the company`s pending confidential
treatment request (the "Application").  The pending Application
was
filed in connection with certain portions of Exhibit 10.1 to the
company`s annual report on Form 10-K, as amended, for the fiscal
year
ended December 31, 2005.

The staff`s comments, if any, on the Application for confidential
treatment will be provided in a separate letter.  Please be aware
that
the effectiveness of the above-captioned registration statement is
dependent on, among other things, the successful resolution of any
issues relating to the Application for confidential treatment.

General

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing
includes all information required under the Securities Act of 1933
and
that they have provided all information investors require for an
informed investment decision.  Since the company and its
management
are in possession of all facts relating to a company`s disclosure,
they are responsible for the accuracy and adequacy of the
disclosure
they have made.

      Notwithstanding our comments, in the even the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:


* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in connection with our review of your
filing or
in response to our comments on your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering of
the securities specified in the above registration statement.  We
will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Dorine H. Miller, Financial Analyst at (202)
551-3711 or me at (202) 551-3742, if you have questions regarding
the
above comments.

Sincerely,



Chris B. Edwards
      Special Counsel


cc:	David J. Ketelsleger, Esq.
	McAfee & Taft A Professional Corporation
	10th Floor, Two Leadership Square, 211 North Robinson
	Oklahoma City, Oklahoma   73102

Mr. Reggie Cook
Aduddell Industries, Inc.
October 10, 2006
Page 3



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

         DIVISION OF
CORPORATION FINANCE