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<SEC-DOCUMENT>0000000000-04-032059.txt : 20050513
<SEC-HEADER>0000000000-04-032059.hdr.sgml : 20050513
<ACCEPTANCE-DATETIME>20041006105022
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-04-032059
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20041006

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			GENERAL BEARING CORP
		CENTRAL INDEX KEY:			0001026221
		STANDARD INDUSTRIAL CLASSIFICATION:	BALL & ROLLER BEARINGS [3562]
		IRS NUMBER:				132796245
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		44 HIGH ST
		CITY:			WEST NYWACK
		STATE:			NY
		ZIP:			10994
		BUSINESS PHONE:		9143586000

	MAIL ADDRESS:	
		STREET 1:		C/O GENERAL BEARING CORP
		STREET 2:		44 HIGH ST
		CITY:			WEST NYACK
		STATE:			NY
		ZIP:			10994
PUBLIC REFERENCE ACCESSION NUMBER:		0001193805-04-001556
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>genbearing8kltr10062004.txt
<DESCRIPTION>10/6/2004 COMMENT LETTER #1; ITEM 4.01, 8-K; HOUSER
<TEXT>


October 6, 2004

David L. Gussack
Chief Executive Officer
General Bearing Corporation
44 High Street
West Nyack, New York  10994

RE:  	Form 8-K Item 4.01 filed October 5, 2004
	File # 0-22053

Dear Mr. Gussack:

We have reviewed your filing and have the following 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.  After
reviewing this information, we may or may not 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 on any other aspect of
our review.  Feel free to call us at the telephone number listed at
the end of this letter.

1. Please amend your Item 4.01, Form 8-K for the following:
* The specific date Urbach Kahn & Werlin LLP resigned as your
independent auditors, as required by Item 304(a)(1)(i) of Regulation
S-K.
* The two fiscal years (i.e., fiscal years ended January 3, 2004 and
December 28, 2002) in which you refer to in your disclosure required
under Item 304(a)(1)(ii) of Regulation S-K.
* The two fiscal years and the subsequent interim period (i.e., fiscal
years ended January 3, 2004 and December 28, 2002 and January 4, 2004
through October 4, 2004) in which you refer to in your disclosure
required under Item 304(a)(1)(iv) of Regulation S-K.

2. To the extent that you make changes to the Form 8-K to comply with
our comments, please obtain and file an updated Exhibit 16 letter from
the former accountants stating whether the accountant agrees with the
statements made in your amended Form 8-K.

*****

Please file your supplemental response and amendment via EDGAR in
response to these comments within 5 business days of the date of this
letter.  Please note that if you require longer than 5 business days
to respond, you should contact the staff immediately to request
additional time.  Direct any questions regarding the above to the
undersigned at (202) 942-1989.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to be
certain that they have provided all information investors require.
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 disclosures they have made.

	In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* 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.

	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 our review of your filing or in response to
our comments on your filing.

Sincerely,




Tracey Houser
Staff Accountant
Mr. Gussack
General Bearing Corporation
October 6, 2004
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

       DIVISION OF
CORPORATION FINANCE




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