UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE


Mail Stop 5546
								March 7, 2006

Via Facsimile (704) 752 7436 and US Mail

Christopher J. Kearney
President and CEO
SPX Corporation
13515 Ballantyne Corporate Place
Charlotte, NC 28277

	Re:	SPX Corporation
		Form 10-K for the Fiscal Year Ended December 31, 2004
      Filed March 16, 2005
 		File No. 1-6948

Dear Mr. Kearney:

      We have limited our review of the above filing to
disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and we will make no further review of
the filing.  Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues.  At this juncture, unless otherwise directed, we are
asking
you to provide us with supplemental information so that we may
better
understand your disclosure.  Please be as detailed as necessary in
your response.  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
filings.
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 numbers
listed
at the end of this letter.

General

1. We note from company websites that you may have operations
associated with Iran, which is identified as a state sponsor of
terrorism by the U.S. State Department.  For example, we note the
contact information of an office in Tehran for customers of SPX
Cooling Technologies GmbH.  Iran is subject to sanctions
administered
by the U.S. Commerce Department`s Bureau of Industry and Security
and
the U.S. Treasury Department`s Office of Foreign Assets Control.
We
note that the Form 10-K does not contain any information relating
to
operations in Iran.  Please describe such operations and discuss
their materiality to you in light of Iran`s status as a state
sponsor
of terrorism.  Please also discuss whether the operations
constitute
a material investment risk to your security holders, and whether
the
impact of regulatory compliance programs associated with business
in
Iran materially affects you.  Your response should describe all
current, historical and anticipated operations in, and contacts
with,
Iran, including through subsidiaries, affiliates, joint ventures
and
other direct and indirect arrangements.

2. Your materiality analysis should address materiality in
quantitative terms, including the approximate dollar amount of
revenues, assets and liabilities associated with Iran.  Please
also
address materiality in terms of qualitative factors that a
reasonable
investor would deem important in making an investment decision,
including the potential impact of corporate activities upon a
company`s reputation and share value.  In this regard, we note
that
Arizona and Louisiana have adopted legislation requiring their
state
retirement systems to prepare reports regarding state pension fund
assets invested in, and/or permitting divestment of state pension
fund assets from, companies that do business with countries
identified as state sponsors of terrorism.  Your materiality
analysis
should address the potential impact of investor sentiment
evidenced
by such actions concerning companies with operations associated
with
Iran.


      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please
understand
that we may have additional comments after reviewing your
amendment
and responses to our comments.  Please file your response letter
on
EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 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 the
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
do not foreclose the Commission from taking any action with
respect
to the filings; 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 filings or
in
response to our comments on your filings.

      Please contact James Lopez at (202) 551-3536 if you have any
questions about the comments or our review.  You may also contact
me
at (202) 551-3470.



								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk




cc: 	Peggy Fisher
		Assistant Director
		Division of Corporation Finance
Christopher J. Kearney
SPX Corporation
March 7, 2006
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