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Proc-Type: 2001,MIC-CLEAR
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<SEC-DOCUMENT>0001193805-04-001575.txt : 20050513
<SEC-HEADER>0001193805-04-001575.hdr.sgml : 20050513
<ACCEPTANCE-DATETIME>20041013135429
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0001193805-04-001575
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20041013

FILER:

	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:		CORRESP

	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
</SEC-HEADER>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>e400823_corresp-gbc.txt
<DESCRIPTION>CORRESPONDENCE LETTER
<TEXT>

October 13, 2004

United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0510

Attn: Ms. Tracy Houser
Staff Accountant

         RE: General Bearing Corporation
             Form 8-K Item 4.01 filed October 5, 2004
             File No. 0-22053

Dear Ms. Houser:

On behalf of General Bearing Corporation (the "Company"), set forth below are
responses to your letter dated October 6, 2004.

Comment # 1

Please amend your Item 4.01, Form 8-K for the following:

o     The specific date Urbach Kahn & Werlin LLP resigned as your independent
      auditors, as required by Item 304 (a) (1) (i) of Regulation S-K.

o     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.

o     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.

We have amended Form 8-K to comply with your comments.

Comment # 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.

We have included the updated Exhibit 16 letter from the former accountants in
the Company's amended Form 8-K.

Closing Comments:

Pursuant to your comments, the Company acknowledges that a) it is responsible
for the adequacy and accuracy of the disclosure filings; b) 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 c) 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.

Pursuant to your request, we will file this response letter on EDGAR.

If you have any questions or require additional information, please call me at
845-358-6000 or fax me at 845-358-6277.

Respectfully yours,


/s/ David Gussack
- -----------------------
David Gussack
Chief Executive Officer

</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
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