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STEN Corporation

13828 Lincoln Street NE

Ham Lake, MN  55304

March 30, 2005

Daniel L. Gordon

Branch Chief

United Stated Securities and Exchange
Commission

450 Fifth Street, N.W.

Washington, DC  20549

Re:                               Sten Corporation

Form 10-KSB for the year ended September 30,
2004

Form 10-QSB for the period ended December 31,
2004

File No. 000-18785

Dear Mr. Gordon:

As requested, we are responding to your
letter dated March 16, 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 8A-Controls and Procedures-Page 15

(b) Changes in Internal Control Over
Financial Reporting

1.                                       We
note your statement that “the Company with the purchase of SOS by its
subsidiary LifeSafe, and with the purchase of Burger Time Corporation through
its BTAC subsidiary, reviewed their existing internal controls and procedures
and determined that that they were adequate and incorporated these internal
controls and procedures the Company’s financial reporting structure.” Please
note that we have not objected to this disclosure since you were not required
to include management’s assessment of the effectiveness of your internal
control over financial reporting in this Form 10-KSB. Please also note,
however, that you will be required to include a statement as to the
effectiveness, rather than the adequacy, of your internal control over
financial reporting in all future filings in which you are required to include
the internal control over financial reporting disclosures called for under Item
308(a) of Regulation S-B.  Please prepare
your future filings accordingly.

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The Company will prepare its future filings
to include a statement as to the effectiveness of the Company’s internal
controls over financial reporting, as such statements are required by Item
308(a) of Regulation S-B.

Notes to Consolidated Financial Statements

Note 1.  Nature of Business and
Summary of Significant Accounting Policies-Page F-6

Intangible Assets

2.                                       We
see you have capitalized assigned sales contracts, net of $55,000 and other
intangible assets of $109,512 as of September 30, 2004. Tell us
supplementally and revise future filings to address the following:

a.                                       Describe
to us the nature of “other” intangible assets and tell us if these intangible
assets are subject to amortization.

The “other” intangible assets of $109,512 as
of September 30, 2004 consists primarily of developmental artwork, designs
and costs associated with setting up the Company’s website for revenue
generating activities and electronic storefronts.  These costs have been capitalized based on
the future benefit expected and the lives of these assets do have a
determinable life.  Amortization had not
begun on these assets because the projects were not yet completed.  Subsequent to September 30, 2004, the
Company sold $91,892 of these intangibles to Aspen Medical Group as part of the
sale of its Medical Products Group.  The
remaining value of the other intangibles of $17,620 will be subject to
amortization in fiscal 2005 with an estimated useful life of 5 years.

b.                                      Explain
to us why it is appropriate to capitalize assigned sales contracts and provide
to us the useful life that you amortizing these contracts over.

The Company purchased assets of Lifekit.com
in July 2004.  As part of the
purchase price allocation, $60,000 of the fair value of the intangible assets
purchased was allocated to the value of existing sales contracts.  The sales contracts are with two major
customers with LifeKit.com for a commitment to provide products over a 28 month
period.  The Company has estimated the
useful life of the sales contracts to be 24 months, which is the estimated period
the sales contracts will contribute to the cash flows of the Company.

Revenue Recognition and Shipping and Handling
Costs

3.                                       Tell
us supplementally and revise future filings to address the following related to
your revenue recognition policies:

a.                                       Describe
how your revenue recognition policy meets all of the criteria of SAB Topic 13A.

Future filings will include our revenue
recognition policy as follows:

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“The Company recognizes revenue in accordance
with Staff Accounting Bulletin No. 104 (SAB 104), “Revenue Recognition”.  SAB 104 requires revenue to be recognized
when all of the following are met: a) persuasive evidence of an arrangement
exists; b) delivery has occurred or services have been rendered; c) the seller’s
price to the buyer is fixed or determinable; and d) collectibility is
reasonable assured.

The Company records sales revenue for the
Contract Manufacturing and LifeSafe business segments at the time all
merchandise is shipped, contractual obligations have been substantially met and
title and risk of loss have passed to the customer.  For the LifeSafe business segment, the sales
revenue is recognized over the period covered by the subscription payment made
pursuant to the customer service agreement which in most cases is for a term of
one year, however, some customers make payments covering shorter periods and
the revenue is recognized over the subscription period covered by the
payment..  Revenues from the BTAC segment
is recognized at the time the food is served.

The Company records amounts being charged to
customers for shipping and handling as sales in accordance with Emerging Issues
Task Force (EITF) Issue 00-10, Accounting for Shipping and Handling Fees and
Costs.”  Shipping and handling costs
incurred by the Company related to the Medical Products Group are included in
cost of goods sold.”

b                                         Describe
any significant terms with your customers including distributors such as
installation obligations, acceptance criteria, unusual pricing or payment terms
and return policies. Your response and disclosure should clarify why it is
appropriate to recognize revenue upon shipment. To the extent necessary for an
understanding of your accounting for these items, please cite the accounting
literature you relied upon.

The Company’s terms of payment are net 30
days for all business segments except for the Burger Time business segment
where payment is due upon delivery of the food.
The Company does not have any installation obligations, acceptance
criteria, unusual pricing or payment terms and return policies with its
distributors.  Returns from distributors
are minimal.  The Company is recognizing
revenue from its distributors in accordance with SAB 104.

c.                                       Since
you perform contract manufacturing, discuss how you present revenue on a gross
or net basis and why this presentation is appropriate.  Refer to EITF 99-19.

In accordance with EITF 99-19, “Reporting
Revenue Gross as a Principal versus Net as an Agent”, the Company is reporting
its sales properly as gross.  As noted in
EITF 99-19, the Company is the primary party responsible for fulfillment of the
product and acceptability by the customer; owns, has physical possession, and

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risk of loss related to the inventory; risk
of obsolescence on inventory owned; and bears the risk if the customer does not
pay.  The Company’s sales with the
contract manufacturing segment meets the definition of EITF 99-19 and is
properly recognizing the sales on the gross amount billed to the customer.

Segment Reporting

4.                                       Revise
future filings to include the qualitative information required by paragraph 26
of SFAS 131. For instance, you should describe the factors used to identify the
your reportable segments, including how management has chosen to organize the
enterprise around differences in products and services, geographic areas,
regulatory environments, or a combination of factors and whether operating
segments have been aggregated.

Future filings will be revised to include the
following disclosure as part of the Segment Reporting disclosure:

“The Company reports its results in three
business segments: Corporate and Contract Manufacturing, LifeSafe and
BTAC.  The Corporate and Contract
Manufacturing segment includes the company’s manufacturing of sterilization
containers and filters.  LifeSafe
business segment includes selling and servicing of emergency oxygen tanks and
other related emergency equipment.  BTAC
business segment is a chain of fast food restaurants.  The Company has identified these business
segments based on the fact that each segment is involved in a different type of
industry, sells different types of products or services and each segment has
distinct customers.

The following table sets forth certain
financial information for each of our business segments described above:”

Note 9.
Stockholder’s Equity-Page F-17

5.                                       We
see that you have issued five-year options to purchase 60,000 shares at $6.00
to a non-employee consultant. Tell us supplementally and revise future filings
to address the following:

a.                                       Clarify
if you recognized the compensation expense over the vesting period or the
contract period.  For instance, do the
options vest over the same term that the services are provided within the consulting
agreement? Disclose in future filings the assumptions utilized in the Black
Scholes model for these options.

Future filings will be revised to include the
following disclosure:

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“These options were valued at $2.71 using the
Black Scholes pricing method with the following assumptions: risk free interest
rate of 5%, expected volatility of 70%, expected dividend yield of 0% and
expected life of options of 3 years.  The
value of the options were initially being expensed over the vesting term of
three years which equals the contract period in conjunction with the sale of
the Medical Products Group to Aspen the Consulting Agreement was cancelled.”

b.                                      In
this regard, we also note in your subsequent Form l0-Q that you disclose the
employee consulting agreement was canceled. Tell us supplementally how you
accounted for the cancellation of the consulting agreement and the previous
expense recognized.

The Company non-employee consulting agreement
was cancelled in connection with the sale of certain assets to Aspen
Surgical.  No additional options will
vest in connection with the termination of the consulting agreement.  The Company did not adjust the expense that
was previously recognized.  For the value
of the options that was not vested, the Company recorded an adjustment to
additional paid-in capital with an offset to the deferred compensation equity
account.

c.                                       Please
revise the notes to the financial statements in future filings to clearly
indicate your accounting policy for equity instrument issuances to
non-employees. We assume you apply FAS 123 and EITF 96-18.

Future filings will be revised to include the
following disclosure:

“Pursuant to EITF 96-18, “Accounting for
Equity Instruments that are Issued to Other Than Employees for Acquiring, or in
Conjunction with Selling, Goods or Services,” and FAS 123, the Company will
value and record an expense related to the options on the date a performance
commitment is met or the date the performance is complete.  The Company currently does not have
outstanding any options issued to non-employees that are to be earned or vested
based on specific milestones being achieved.”

6.                                       We
see your disclosure that you issued warrants to purchase the Company’s common
stock at $4.00 per share, which were set to expire on September 29, 2003
and were extended to September 30, 2005. Tell us supplementally and revise
future filings to provide how you valued, recorded and accounted for the impact
of the modification, if any.

There was no accounting impact for the
extension of the warrants term to September 30, 2005.  These warrants were issued to public
shareholders in connection with their participation in a shareholder rights
offering.  In that offering, shareholders
who purchased a “unit” obtained a share of stock and a warrant to purchase
one-half share of stock at the equivalent of $4.00 per share.  The Board approved the extension of the
warrant term so as to encourage exercise of the warrant.  Since the warrants extended related to a
previous equity

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transaction, and the price was not adjusted,
the Company determined that no accounting adjustments were necessary.

Form 10Q-SB for the quarter ended December 31,
2004

Assets of Discontinued Business Held of Sale

7.                                       We
see that you classified your building related to your medical products supply
of $722,856 as held for sale as of December 31, 2004. Tell us
supplementally how you meet the requirements of paragraph 30 of SFAS 144 to
present this an asset held for sale.

The Company meets all of the criteria set
forth in paragraph 30 of SFAS 144.  After
the sale of certain assets to Aspen Surgical, management, having the authority,
is holding the building for immediate sale in its present condition subject
only to terms that are usual and customary for the sale of the building.  The Company is active in its pursuit to sell
the building.  A “For Sale” sign is in
front of the building and the set price is reasonable based on the surrounding
property and its current fair value.  The
plan is to sell the building as soon as possible and the Company does not
foresee removing the property from the market or changing its plan.  The Company anticipates the building being
sold within one year.

Note 13.
Discontinued Operations-Page F-14.

8.                                       Tell
us supplementally and revise future filings to address the following related
your discontinued operations:

a.                                       Describe
to us how you meet the conditions within paragraph 42 of SFAS 144 to report
this sale as discontinued operations.

The Company meets the criteria set forth
within paragraph 42 of SFAS 144 since the operations and cash flow of the
Medical Products have been eliminated and the Company does not have any
continuing involvement in the operations after the sale.  All of the inventory and operations have been
moved as of December 31, 2004 to the Aspen Medical Group location and the
Company is not involved in the operations going forward.  The Company will not be receiving any ongoing
royalties or other incentives from the sale going forward.  The Company reviewed EITF 03-13, “Applying
the Conditions in Paragraph 42 of FASB Statement No. 144 in Determining Whether
to Report Discontinued Operations” and believes the result of operations of the
Medical Products qualifies as discontinued operations.

b.                                      Clarify
how your shutdown expenses of $342,259 reconciles to the severance costs of
$100,000 and transaction, legal and transition costs of $322,791 presented
within your tabular presentation of the calculation of your income (loss)
recognized from your discontinued operations for the period ended December 31,
2004.

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As part of the sale agreement with Aspen
Medical Group, the $342,259 represents a benefit the Company received when
Aspen Surgical paid for inventory and other identifiable expenses related to
the Medical Products Group that were already in the Company’s Accounts
Payables.  The $342,259 is not related to
the Company’s shut down expenses.  A
reconciliation of the $322,791 is presented in section d of this note.

c.                                       We
also note that you have presented $848,317 of liabilities from