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Innovex, Inc.

5540 Pioneer Creek Drive

Maple Plain, Minnesota  55359

June 30, 2005

VIA EDGAR

Mr. Jay Webb

Reviewing Accountant

Securities and Exchange Commission

Mail Stop 03-06

Washington, D.C.  20549

Re:       Innovex, Inc.

Form 10-K for the fiscal year ended September 30, 2004

Form 10-Q for the quarters ended December 31, 2004 and March 31,
2005

File No. 000-13143

Dear Mr. Webb:

As requested, we are responding to your letter dated June 17,
2005.  For convenience and clarity, we
have set forth the text of your comments below.
We are responding to the comments in the order presented.

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 equity.

•                                          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 your explicit or implicit
guarantees.

Innovex owns 35% of AKI’s outstanding shares.  The remaining 65% of AKI’s outstanding shares
are held by five individuals who are AKI employees, officers and founding
shareholders

(the “Inside Shareholders”).
Each of the Inside Shareholders holds 13% of the outstanding
shares.  The Inside Shareholders vote
their 65% combined ownership as a block and have controlling interest of AKI.  This information was provided to Innovex
management by AKI management and is also based on a review of AKI Board of
Director Minutes.

Innovex does not have a controlling financial interest in AKI through
the license agreement.  The License
agreement was negotiated and approved for AKI by the AKI Inside Shareholders
who do not have a financial interest in Innovex.  AKI would remain a viable, profitable entity
without the royalties from the Innovex/AKI license agreement.  Supplementally, and in support of its
conclusion, Innovex will provide to the Commission’s staff AKI’s financial
statements for the first eleven months of fiscal 2005 ending May 31,
2005.  These AKI financial statements
were received by Innovex as a shareholder of AKI.

Innovex believes that AKI has sufficient equity at risk to finance its
activities without additional financing from Innovex.  The financial statements demonstrate that AKI
has substantial equity and cash that greatly exceeds its outstanding debt.  Further, AKI’s only debt outstanding is the
balance remaining on notes payable to the AKI Inside Shareholders related to
AKI’s repurchase of shares from the Inside Shareholders which occurred
concurrent with Innovex’s purchase of it 35% minority shareholder
position.  AKI is operating profitably
and does not require any additional financing from Innovex.  Innovex does not have an obligation to
provide any additional financing to AKI.

Innovex does not have any arrangements or activities that have created
any explicit or implicit guarantees to AKI to provide any additional financial
support.  We believe no implicit
guarantees exist because we have no economic motive to do so and it would be
outside of our conflict of interest policies to do so.

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.

The Company hereby confirms that, in future filings, it will provide
the requested disclosures in response to your previous Comment No. 5.

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

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.

The Company hereby confirms that, in future filings, it will provide
the discussion requested in your previous Comment No. 6.

Please contact
Thomas Paulson, Chief Financial Officer, or Douglas W. Keller, Vice President,
Finance, at (763) 479-5300or by facsimile at (763) 479-5395 if you have any
questions or need additional information.

  Very Truly
  Yours,

  INNOVEX,
  INC.

  /s/ Thomas
  Paulson

  Thomas
  Paulson, Chief Financial Officer

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