SecProbe.io

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                               [ISSUER LETTERHEAD]

May 9, 2005

Mr. Brian Cascio
Accounting Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 0306
Washington, C.C. 20549

RE:      ASI Technology Corporation
         Form  10-KSB  for the  fiscal  year ended  December  31,  2004 File No.
         000-06428

Dear Mr. Cascio:

This letter is in response to staff comments dated April 25, 2005.

We acknowledge on behalf of the company that:

     o   the  company  is  responsible  for the  adequacy  and  accuracy  of the
         disclosure in the filings;
     o   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
     o   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.

The itemized  responses  below respond to the same comment number  enumerated in
your letter dated April 25, 2005.

1.       We will revise future  filings to  separately  state on the face of the
         financial  statements the tax provision or benefits associated with our
         discontinued  operations in accordance  with  paragraph 43 of SFAS 144.
         Please  note  that  due  to a full  valuation  allowance  on  tax  loss
         carryforwards  from the  uncertainty of realizing any related  benefits
         that the  related  tax  benefit or  provision  in each prior  reporting
         period was nil.

2.       The contracts  formerly performed for the government were Department of
         Defense  SBIR  (Small  Business  Innovation  Research)  or STTR  (Small
         Business   Technology   Transfer)   contracts.   These  generally  were
         Firm-Fixed  Price,  Level-of-Effort  Term  Contracts  providing  for  a
         specific  level  of  effort  in  terms  of  hours  and a  final  report
         discussing results achieved. A total number of hours was determined for
         the contract and an all inclusive rate was negotiated to include costs,
         overhead  and  profit.  Interim  billings  were paid to us based on the
         number of hours or effort  expended.  Generally  the only  deliverables
         were written  reports  describing  the research  conducted  and results
         achieved. Statement of Financial Accounting Concepts No. 5 "Recognition
         and  Measurement  in  Financial  Statements  of  Business  Enterprises"
         paragraph 83 and 84 provides for revenue  recognition when services are
         performed.

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         Although ARB #43, Chapter 11 deals primarily with Government  Contracts
         that are Cost  Plus  Fixed Fee it  outlines  criteria  for  recognizing
         profit  based  on  partial  performance  due  to  the  nature  of  such
         contracts.  As our fees  were  earned  and  billable  based on hours or
         effort expended,  we recognized  revenue on a percentage of total hours
         or effort  expended for each  contract  which also tracked  closely the
         percentage of costs and profit inherent in the contract.  We believe we
         meet the criteria in  paragraphs 23 through 29 of SOP 81-1 to recognize
         revenue on the percentage of completion method.

         We  believe  the  revenues  were  properly  recognizable  and earned as
         services  were  perfomed  on a  percentage  basis  given  the above and
         general  standards  of  revenue  recognition.   The  contract  provided
         persuasive  evidence  of  our  arrangement  with  the  government.   We
         delivered the hours or efforts and reports  periodically as provided by
         each contract.  These hours or efforts were fixed,  set as to price and
         determinable  both in the aggregate and on a periodic basis.  And being
         an awarded government contract we believed  collectibility was assured.
         Although the contracts had standard government cancellation clauses, as
         discussed in ARB #43 this  generally  allows for  retention of payments
         earned.  Generally these were 6-12 month contracts and are not normally
         cancelled  once awarded as they relate to one budget  allocation by the
         Government.

         Once the contract was  completed and the final report  delivered  there
         was no post  development  contract  support  required,  contemplated or
         provided. Our last contract was completed in April 2004.

3.       The gain on sale of discontinued operations in 2003 was computed as the
         gross proceeds  received (Cash of $150,000 and Markland common stock of
         $850,000) of $1,000,000  less the patent and license  royalty fees paid
         to others aggregating $60,000 as individually  enumerated in the second
         paragraph  of Note 3 to our  financial  statements.  The net  gain  was
         $940,000  as  reported.  See  answer  4  below  for  the  valuation  of
         securities  information.  There  were  no  other  costs  affecting  the
         computation of the gain.

         In March 2004 we received 39,950 shares of Markland common stock valued
         at $62,722 as  additional  consideration  for a failure by  Markland to
         timely  register  the shares we  previously  received  from the sale of
         technology. These shares, valued at the quoted market price of $1.57 or
         an  aggregate  of $62,722,  were  recorded as  additional  proceeds and
         increased the total aggregate gain from $940,000 to $1,002,722.

4.       The initial  valuation of securities  received in  connection  with the
         sale was recorded as $850,000  before the royalty and fees described in
         response 3 above and in Note 3 to our financial statements. We received
         a total of  283,333  shares  (post 1 for 60 reverse  split by  Markland
         effected  October 27, 2003).  Pursuant to Section 2a of the  Technology
         Purchase  Agreement with Markland  (Exhibit 10.5 to our filing) we were
         to receive at the final  closing "a number of shares of the  Securities
         having  an  aggregate  market  value of  $850,000."  We  received  from
         Markland  17,000,000  pre-split  shares on July 10,  2003  representing
         Markland's share payment. We noted that Markland valued these shares in
         their public  filings at $850,000.  We also noted the closing  price on
         July 10, 2003 was $0.05 per share or also equal to the  $850,000 in the
         aggregate.

         As these shares met the  definition of marketable  securities  for SFAS
         #115, being they were not restricted beyond one year (or less given the
         registration  rights),  management  valued the securities at the quoted
         market price on the date of receipt or $850,000.

                                  Page 2 of 3

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         In March 2004 we received a net of 39,950 shares (post  reverse  split)
         of Markland  common stock valued at the quoted market price on the date
         of receipt of $1.57 or an aggregate of $62,722 as  additional  proceeds
         for late  registration.  This increased the total gain from $940,000 to
         $1,002,722.

         There were a number of circumstances that resulted in the conclusion of
         impairment  in third  quarter of 2004.  As reported in Footnote 4 there
         was a substantial decline in the value of the investment securities and
         there was no  assurance  of future  recovery  in value.  The decline in
         value was  evidenced  by viewing  the stock chart for  Markland  common
         stock  showing a price of $1.50 or more in the first  half of  calendar
         2004 deteriorating to the $.50 level in August and September of 2004.

         At the time we evaluated  impairment  for our June 2004 quarter we were
         encouraged  by  Markland's  report of new financing of $11.7 million in
         April and May 2004 and a report of $4.7  million  in  revenues  in July
         2004.  However in September and October of 2004 (when Markland reported
         June 2004 fiscal  results)  evidence  indicating  uncertainty of future
         recovery of the price included  increased  losses reported by Markland,
         $3.1  million  loss in the March 2004  quarter and $5.6  million in the
         June 2004  quarter,  and a lack of cash  indicated by a balance of less
         than  $1.1  million  at June  2004.  At the same  time,  the  number of
         Markland common shares outstanding increased from 3,671,573 at June 30,
         2003 to 31,856,793 at June 30, 2004 indicating less likelihood of price
         recovery  even if  financial  results  improved  at some  point  in the
         future.  A  registration  statement  filed in May  2004 for 32  million
         shares  evidenced  to us  additional  future  supply  of stock  further
         indicating little likelihood of price recovery in the future.

         Lastly,  given our potential  future cash needs, we were uncertain that
         we  would  be able to  hold  the  securities  for  the  period  of time
         sufficient for the price to recover to its cost basis. Therefore in the
         third  quarter of 2004,  we concluded  that it was probable we would be
         unable to recover our cost basis, so the cost basis was written down to
         the September 30, 2004 quoted market price.

5.       We will revise future  filings to provide more specific  details of our
         plan of  operations.  This will  include  specifics  as to time frames,
         funding needs and sources and other matters  related to the development
         of our  technology.  We will  also  discuss  the  impact  if we are not
         successful in our efforts.

We have filed this response on Edgar as requested.  Please note that we have not
amended the Form  10-KSB for the year ended  December  31, 2004 or any  existing
filings as a result of these  comments at this point.  Please  contact us if you
have  any  questions  about  our  responses  noted  above.  Our  fax  number  is
702.737.6900 and the telephone number is 702.734.1888.

Sincerely,

/s/ ERIC M. POLIS
-----------------
Eric M. Polis
Treasurer and Principal Financial Officer

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