SecProbe.io

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Mail Stop 0306

March 10, 2005

Via U.S. Mail and Facsimile to (651) 638-0477

Scott P. Youngstrom
Chief Financial Officer
Compex Technologies, Inc.
1811 Old Highway 8
New Brighton, MN 55112

	Re:	Compex Technologies, Inc.
		Form 10-K for Fiscal Year Ended June 30, 2004
Forms 10-Q for Fiscal Quarters ended September 30, 2004, and
December
31, 2004
      File No. 000-09407

Dear Mr. Youngstown:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do no intend to expand our review to other
portions of your documents. Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
or may not 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the Fiscal Year Ended June 30, 2004

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations - Page 21

Comparison of Year Ended June 30, 2004 to Year Ended June 30, 2003
-
Page 23

1. We see that your earnings for fiscal 2004 significantly
benefited
from "resolution of various outstanding tax issues."  In future
filings please make more specific disclosure about this matter.
You
should provide some discussion about the nature of the tax issues
resolved, including disclosure about why the timing of the benefit
is
appropriate.

2. With respect to accruals for income contingencies, paragraph 9
of
FAS 5 states that disclosure of the nature of a contingency
accrual
and, in some circumstances the amount accrued, may be necessary
for
the financial statements not to be misleading.  The notes to
financial statements should include a reasonably transparent
description of the nature of any accruals for income tax
contingencies.  As well, disclosures about any material amounts
should also reflect the requirements of paragraphs 13 and 14 of
SOP
94-6.  We are aware, for instance, that multinational companies
often
have material accruals for transfer pricing and other cross-border
exposures. Expand your disclosures in future filings or tell us
how
your disclosures about tax contingencies comply with GAAP.

Item 8. Financial Statements - Page 28

1. Summary of Significant Accounting Policies - Page 34

Revenue Recognition and Provisions for Credit Allowances and
Returns
- Page 34

3. With respect to the domestic medical business you state that
many
insurance providers reimburse you at rates which differ from your
invoiced rates and that the nature of receivables within the
insurance industry results in long collection cycles. We also see
the
significance of the activity in the credit reserve account as set
forth in the Valuation and Qualifying accounts schedule. SAB 104
requires that the sales price be fixed or determinable and that
collectibility be reasonably assured before revenue is considered
realized and earned. Considering these factors, please tell us how
recognizing revenue at the point of shipment or at the time of
prescription complies with SAB 104.  That is, tell us more about
why
you believe the sales price is subject to reasonable estimation at
the time of prescription or shipment.

4. Unless insignificant in amount, please expand future filings to
also address rental revenues and costs.

5. With respect to sales in Europe and international markets,
please
expand future filings to describe how you estimate sales
allowances
and returns.  Also describe the nature and extent of any
significant
uncertainties associated with those estimates.

2. Business Acquisition - Page 40

6. We see that you acquired Filsport Assistance S.r.l. on July 3,
2003.  For material business combinations, please ensure that
future
filings include the primary reasons for the acquisitions,
including a
description of the factors that contributed to a purchase price
resulting in the recognition of goodwill.  Refer to paragraph 51b
to
FAS 141.

Item 9A. Controls and Procedures - Page 48

7. We see disclosure that management has concluded that disclosure
controls and procedures are effective "in timely alerting them to
the
material information relating to us required to be included in the
reports we file or submit under the Exchange Act."   Please revise
future filings to delete the language after the word "effective."
Alternatively, please revise future filings so that the language
appearing after the word "effective" is substantially similar to
the
language that appears in the entire two-sentence definition of
"disclosure controls and procedures" set forth in Rule 13a-15(e).

Schedule II - Valuation and Qualifying Accounts

8. With respect to the "Additions" column, please revise future
filings to clarify amounts recorded as sales allowances (reduction
of
revenue) versus bad debt expense.  Please also further clarify the
nature of the "Deductions."  Are these charges against the reserve
for uncollected amounts or are "reversals" also included in those
totals?

Form 10-Q for the Fiscal Quarters Ended December 31, 2004

Item 4. Controls and Procedures - Page 20

9. We see that management concluded that disclosure controls and
procedures are "effective to ensure that information [you] are
required to disclose in the reports that [you] file or submit
under
the Securities Exchange Act of 1934 are recorded, processed,
summarized, and reported within the time periods specified in the
Securities and Exchange Commission rules and forms."  Please
revise
future filings to clarify, if true, that your officers concluded
that
disclosure controls and procedures are also effective to ensure
that
information required to be disclosed in reports filed or submitted
under the Exchange Act is accumulated and communicated to
management,
including your chief executive officer and chief financial
officer,
to allow timely decisions regarding required disclosure.  See
Exchange Act Rule 13a-15(e).

* * * * *

       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 that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a 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 filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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 filing or in
response to our comments on your filing.

      You may contact Kevin Kuhar, Staff Accountant, at (202) 824-
5579 or me at (202) 942-2862 if you have questions regarding these
comments on the financial statements and related matters.  In this
regard, do not hesitate to contact Brian Cascio, Branch Chief, at
(202) 942-1791.

							Sincerely,

							Gary Todd
							Reviewing Accountant
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Mr. Scott P. Youngstrom
Compex Technologies, Inc.
March 10, 2005
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