SecProbe.io

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Mail Stop 0610

		June 17, 2005

Via U.S. Mail and Facsimile to (763) 479-5395

Thomas Paulson
Chief Financial Officer
Innovex, Inc.
5540 Pioneer Creek Drive
Maple Plain, MN 55359

	Re:	Innovex, Inc.
		Form 10-SBK for Fiscal Year Ended September 30, 2004
Forms 10-Q for Fiscal Quarters Ended December 31, 2005 and
March 31, 2005
      File No. 000-14143

Dear Mr. Paulson:

      We have reviewed your response and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-KSB for the Fiscal Year Ended September 30, 2004

Item 1. Business, page 1

Research and Development, page 5

1. Please refer to prior comment 1. We note your response that you
do
not feel the requirements of FIN 46(R) would alter your accounting
for your investment in AKI. Please provide us detail and support
for
your following conclusions:

* Equity investors in AKI do have controlling financial interest
in
the entity.
* Controlling financial interest is not achieved through other
arrangements, such as your license agreement.
* AKI has sufficient equity at risk to finance its activities
without
additional financing from you.
* That your arrangements and activities do not create any explicit
or
implicit guarantees.

Form 10-QSB for the Fiscal Quarter Ended March 31, 2005

Part 1: Item 1: Financial Statements, page 3

Note 2 - Restructuring Charges, page 6

2. Please refer to prior comment 5. We note that your response
appeared to adequately address our comment, however, upon review
of
your March 31, 2005 Form 10-QSB, it appears you did not provide
the
additional disclosure as requested. Accordingly, please confirm
that
you will provide the previously requested disclosures in your
future
filings.

Part 1: Item 2: Management`s Discussion and Analysis of Financial
Condition and Results of Operations, page 9

Cost and Expenses, page 10

3. Please refer to prior comment 6. We note that your response
appeared to adequately address our comment, however, upon review
of
your March 31, 2005 Form 10-QSB, it appears you did not provide
the
addition discussion as requested. Accordingly, please confirm that
you will provide the previously requested disclosures in your
future
filings.

As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response.  Please
furnish a cover letter with your response that keys your responses
to
our comments and provides any requested information.  Detailed
cover
letters greatly facilitate our review.  Please file your cover
letter
on EDGAR.  Please understand that we may have additional comments
after reviewing your responses to our comments.

      You may contact Kevin Kuhar, Staff Accountant, at (202) 551-
3662 or me at (202) 551-3603 if you have questions regarding these
comments.  In this regard, do not hesitate to contact Angela
Crane,
Branch Chief at (202) 551-3554.

						Sincerely,

								Jay Webb
								Reviewing Accountant

Thomas Paulson
Innovex, Inc.
June 17, 2005
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