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corresp

June 3, 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

    File No. 000-09407

Dear Mr. Todd,

In the pages attached, we have included our responses to your comments from
your letter dated May 24, 2005, regarding our form 10-K for fiscal year-ended
June 30, 2004 and for forms 10-Q. 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

1. Summary of Significant Accounting Policies — Page 34

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

    1.
    Refer to your response to previous Comment 3. For the sales of
medical products in the United States, you disclose that you
establish a reserve for sales allowances, product returns and
rental credits at the time of revenue recognition. However, you
indicated that “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.”
Tell us why returns are not applied against the reserve
established at sale. Clarify the basis for the accounting
supplementally.

COMPANY RESPONSE:

For patient returns of products after a purchase, which have
previously been recorded as unit sales revenue, the gross
revenue is reduced in the current period. Additionally, after
this reversal of unit sales revenue, the patient and insurer are
billed for rental of the unit for the period of time that the
patient possessed the unit. The patient is returning the unit
for various reasons such as high patient deductible or because
the unit was ineffective. The Company does not apply it against
the sales reserve as it does not affect our ability to collect,
but rather an issue of the patient not wanting the unit. The
Company intends to revise and expand wording on this situation
as it relates to the Revenue Recognition Policy to be included
in our notes to financial statements.

    2.
    For international sales of products to health care providers
you identify that revenue is recognized at the time of shipment
or upon notification from a health care provider that the
equipment has been prescribed and provided to the patient. Tell
us more about the arrangements with the health care providers.
Do you have consigned contracts with them? How do you determine
whether to recognize revenue upon shipment to the provider or
upon prescription to the patient? Please also clarify the
disclosure in future filings.

COMPANY RESPONSE:

For international sales of medical products, the Company
recognizes revenue at the time of shipment after receiving a
prescription from the doctor or the health care provider. The
Company does not maintain any consigned medical devices in any
of its international locations. The Company receives directly
from the doctor or health care provider, a prescription,
directly to its corporate office. After receiving the
prescription, the Company determines whether the patient or
their insurance provider should be invoiced and then sends the
unit to the patient. Revenue is recognized at this time. The
Company intends to revise and expand wording on this situation
as it relates to the Revenue Recognition Policy to be included
in our notes to financial statements.