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March 23, 2005

Gary Todd — Reviewing Accountant

Division of Corporation Finance

United States Securities & Exchange Commission

450 — 5th Street, N.W.

Washington, DC 20549-0306

    RE:

    Compex Technologies, Inc. (41-0985318)

    Form 10-K for fiscal year ended June 30, 2004

    Forms 10-Q for fiscal quarters ended September 30, 2004 & December 31, 2004

    File No. 000-09407

Dear Mr. Todd,

In the pages attached, we have included our responses to your comments from your letter dated March
10, 2005, regarding our form 10-K for fiscal year-ended June 30, 2004 and for forms 10-Q for fiscal
quarters ended September 30, 2004 and December 31, 2004. We have listed each of your comments in
order followed by our “Company Response”.

The company acknowledges that we are responsible for the adequacy and accuracy of the disclosure in
the filings. We acknowledge that 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.

We have not and do not plan to revise any previously filed documents. We will, however, expand or
revise our disclosure in all future filings when deemed appropriate.

We anticipate our explanations will meet your expectations, however if you have any questions or
would like to discuss this with me further, please contact me via phone at (651) 638-0428 or via
fax at (651) 638-0477.

Sincerely,

Scott P. Youngstrom

Chief Financial Officer

Enclosure

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" -->

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.

    COMPANY RESPONSE:

We acknowledge your comment and we will expand our disclosure in our future
filings to include the nature of the tax issues resolved and disclose why the
timing of the benefit was 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.

    COMPANY RESPONSE:

We acknowledge your comment and we will expand our disclosure in our future
filings to include the nature of our accruals for income tax contingencies.

Item 8. Financial Statements — Page 28." -->

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.

    COMPANY RESPONSE:

We acknowledge your comment and we will expand our disclosure in our future
filings to include how recognizing revenue at the point of shipment or at the
time of prescription is in compliance with SAB 104 and why we believe the sales
price is subject to reasonable estimation at the time of prescription or
shipment. We believe we have sufficient collection information to estimate a reserve for sales
allowances such that the sales price is determinable at the time of prescription
or shipment. We intend to revise and expand wording of the Revenue Recognition
Policy to be included in our notes to financial statements substantially as
follows:

    Revenue Recognition

    The Company derives revenue in the United States from
medical products and accessories (United States Medical) sales and
rentals directly to patients and to wholesalers. The Company also
derives revenue in the United States from the sales of consumer
products (United States Consumer) to distributors and directly to
consumers. In certain non-domestic markets (International), the
Company derives revenue primarily from the sales of consumer products
to distributors and dealers.

    United States Medical

The direct medical business involves providing products to patients for rent
or purchase, the sale of accessories to patients for the ongoing use of such
products and billing of the patient’s insurance provider for the
products and
accessories. The wholesale medical business involves the sale of devices and
medical supplies primarily to clinics and medical equipment distributors.

    The Company recognizes revenue in accordance with Staff Accounting Bulletin
(SAB) No. 101, as amended by SAB No. 104, when each of the following four
conditions are met: 1) a contract or sales arrangement exists; 2) products have
been shipped and title has transferred or services have been rendered; 3) the
price of the products or services is fixed or determinable; and 4)
collectibility is reasonably assured. Accordingly, the Company recognizes direct
medical revenue, both rental and purchase, when products have been dispensed to
the patient and the patient’s insurance has been verified. For medical products
that are sold from inventories consigned at clinic locations, the Company
recognizes revenue when it receives notice that the product has been prescribed
and dispensed to the patient and the insurance has been verified or
preauthorization has been obtained from the insurance company, when required.
The Company recognizes wholesale medical revenue when it ships its products to
its wholesale customers.

    Revenue from the rental of products to patients accounts for approximately
___% and ___%, respectively, of the United States Medical revenue for the periods
ended ___. Revenue from the rental of products is recognized ratably
based on the number of days remaining in the month. Products on rental
contracts are placed in fixed assets and depreciated over their
estimated useful life. All revenue is
recognized net of estimated sales allowances and returns.

    The Company has established reserves to account for sales allowances, product
returns and rental credits. Sales allowances generally result from agreements
with certain insurance providers that permit reimbursement to the Company in
amounts that are below the product’s invoice price. This reserve is provided for
by reducing gross revenue by a portion of the amount invoiced during the
relevant period. The Company estimates the amount of the reduction based upon
historical experience and considers the impact of new contract terms or
modifications of existing arrangements with insurance providers. For patient
returns of products after purchase, the amount previously recorded as revenue in
a prior period is provided for by reducing gross revenue in the current period.
Rental credits result when patients purchase products that they had previously
rented. Many insurance providers require patients to rent products for a period
of one to three months prior to purchase. If the patient has a long-term need
for the product, the insurance

    companies may authorize purchase of the product by these patients. When the
product is purchased, most insurance providers require that rental payments
previously made on the product be credited toward the purchase price. These
rental credits are processed at the same time the revenue is recorded on the
sale of the product. A change in the percentage of medical sales made pursuant
to such contracts or a change in the number or type of products that are
returned could cause the level of these reserves to vary in the future.

    In addition to the reserves for sales allowances, returns and rental credits,
the Company provides for uncollectible accounts receivable. These uncollectible
accounts receivable are a result of non-payment from patients who have been
direct billed for co-payments or deductibles; lack of appropriate insurance
coverage; and disallowances of charges by third-party providers. The reserve is
based on historical trends, current relationships with providers, and internal
process improvements. If there were a change to a material insurance provider
contract, a decline in the economic condition of patients or significant
turnover of company personnel, the current level of the reserve for
uncollectible accounts receivable may not be adequate and may result in an
increase of these levels in the future.

    United States Consumer

The U.S. consumer products business involves the sales of products to distributors,
sport shops and direct sales to consumers. Revenue is primarily recognized at
the time of shipment to distributors, sport shops and direct sales to consumers.
A portion of the Company’s inventory is out on consignment with certain
distributors and the revenue is not recognized until the distributor sells the
product to a consumer. All revenue is recognized net of estimated sales
allowances and returns.

    The Company has established reserves to account for sales allowances and product
returns. All consumer products are sold with a 30-day, money back guarantee and
the Company estimates the amount of the revenue reduction based upon historical
experience and considers the impact of new contract terms or modifications of
existing arrangements with distributors. In addition to the reserves for
sales allowances and product returns, the Company provides for uncollectible
accounts receivable. These uncollectible accounts receivable are a result of
non-payment from both distributors and direct customers. The reserve is based
primarily on historical trends and specific review.

    International

The international products business involves the sales to sports shops, retail
shops and health care providers. Revenue is recognized at the time of shipment
to dealers, distributors, sport shops and health care providers, direct sales to
consumers or upon notification from a health care provider that equipment has
been prescribed and provided to a patient and approved by the patient or his/her
insurance provider. All revenue is recognized net of estimated sales allowances
and product returns.

    The Company has established reserves to account for sales allowances, product
returns and rental credits. The Company estimates the amount of the revenue
reduction based upon historical experience and considers the impact of new
contract terms or modifications of existing arrangements with distributors.
In addition to the reserves for sales allowances and product returns, the
Company provides for uncollectible accounts receivable. These uncollectible
accounts receivable are a result of non-payment from both distributors and
direct customers. The reserve is based primarily on historical trends and
specific review.

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

    COMPANY RESPONSE:

We acknowledge your comment and we will expand our disclosure in our future
filings to include a discussion on how the company recognizes rental revenues
and associated costs, in markets where it is of a material amount. We will
expand our disclosure in our Revenue Recognition segment to include this
information, if significant in amount. See our proposed, expanded disclosure in
comment #3, above.

    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.

    COMPANY RESPONSE:

We acknowledge your comment and we will expand our disclosure in our future
filings to include how we estimate our sales allowances and returns in our
European and International markets. The Company does not have any significant
uncertainties associated with European and International sales returns and
allowances at the present time. The company will expand our disclosure in
future filings to include the nature and extent of any significant uncertainties
in the estimates when applicable. See our proposed, expanded disclosure in
comment #3, above.

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.

    COMPANY RESPONSE:

We acknowledge your comment and we will expand our disclosure in our future
filings to include the primary reasons for the acquisition and the factors that
contributed to a purchase price resulting in the recognition of goodwill.

Item 9A. Controls and Procedures — Page 48" -->

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).

    COMPANY RESPONSE:

We acknowledge your comment and we will expand our disclosure in our future
filings to read as follows:

    Item 9A.Controls and Procedures.

    Under the supervision and with the participation of our management, including our
Chief Executive Officer and Chief Financial Officer, we evaluated the
effectiveness of the design and operation of our disclosure controls and
procedures (as defined in Rule 13a-15(e) under the Securities Exchange Act of
1934 (the “Exchange Act”)). Based upon that evaluation, the Chief Executive
Officer and Chief Financial Officer concluded that, as of the end of the period
covered by this report, our disclosure controls and procedures were effective.
Disclosure controls and procedures mea