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PPT
VISION, Inc.

12988
Valley View Road

Eden
Prairie, MN  55344

PH:  952-996-9500, FAX:  952-996-9501

April 26,
2005

Attn:  Kate Tillan, Reviewing
Accountant

Mail Stop 0306

Division of Corporation Finance

Securities and Exchange Commission

450 Fifth Street, NW

Washington, DC 20549-0306

Re:                               PPT Vision, Inc.

Form 10-KSB for the Fiscal Year Ended October 31, 2004

Form 10-QSB for Fiscal Quarter Ended January 31, 2005

File No. 000-11518

Dear Ms Tillan:

PPT Vision, Inc.
received your comment letter dated April 6, 2005 related to the filings
listed above.  This letter will respond
to the comments raised by the staff with each response numbered to correspond
to the staff comments.

Form 10-QSB for the quarter ended January 31,
2005.

Item 3.
Controls and Procedures – Page 17

(a) Evaluation of Disclosure Controls
and Procedures

Comment 1

We note your
statement that the chief executive officer and chief financial officer have
concluded that the company’s disclosure controls and procedures are effective
as of January 31, 2005.  However,
you also state that, several days subsequent to the date of your evaluation of
your disclosure controls and procedures, you failed to timely file a proxy
statement.  In light of that untimely
filing, please revise your disclosure to explain how your chief executive
officer and chief financial officer were still able to conclude that your
disclosure controls and procedures were effective as of January 31,
2005.  For example, if true, you can
state that your disclosure controls and procedures were determined to be
effective in light of the untimely filing.
Alternatively, if true, you can state that given the untimely filing,
your disclosure controls and procedures were not effective.

SEC Response No. 1.

Under Rule 13a-15(e),
the term “Disclosure Controls and Procedures” means “controls and other
procedures of an Issuer that are designed to ensure that information required
to be disclosed by the Issuer in the reports that it files or submits under the
[Securities Exchange Act of 1934] is recorded, processed, summarized and
reported within the time frame specified in the Commission’s rules and
forms.  The officers of PPT Vision
believe that the Company’s controls and procedures are effective in ensuring
that proper information particularly with respect to its Forms 10-KSB, 10-QSB
and current reports on Form 8-K are processed and reported in a
timely manner.  The Company also believes
that it correctly included the required information in the Proxy Statement, but
due to an oversight failed to transmit the Proxy to the SEC at the same time as
it was mailed to shareholders.  The
Company believes that apart from its untimely filing, the disclosure controls
were effective.  Accordingly, the Company
would propose to include the following language in its Form 10-QSB
for the quarter ended April 30, 2005.
The Company believe that this disclosure is not dissimilar from that
included in the Form 10-QSB for the quarter ended January 31,
2005 and that there is no compelling reason to amend the Form 10-SB
for the quarter ended January 31, 2005 if appropriate disclosure is
contained in the next Form 10-QSB.

Item 3:  CONTROLS AND PROCEDURES

(a) Evaluation of Disclosure Controls and Procedures.

The Company’s Chief Executive Officer, Joseph C. Christenson and Chief
Financial Officer, Timothy C. Clayton reviewed the Company’s disclosure
controls and procedures as of January 31, 2005 [or April 30,
2005.]   Subject to the information
set forth below in this paragraph, these officers concluded that the Company’s
disclosure controls and procedures were effective.   Subsequent to the end of the quarter [or
during the quarter], the Company determined that it had inadvertently failed to
file its Proxy Statement with the Securities and Exchange Commission on a
timely basis.   This document should
have been filed with the SEC at the time it was mailed to the Company’s
shareholders on February 6, 2005 and due to an oversight, the document was
not filed with the SEC until March 4, 2005.   The Company has implemented new procedures to
prevent this situation from occurring in the future and believes that its
disclosure controls and procedures are effective.

(b) Changes in Internal Control Over
Financial Reporting

Comment 2

We note your
statement that there have been no “other” changes in your internal control over
financial reporting.  Please revise your
disclosure regarding changes in your internal control over financial reporting
to specifically identify each change in your internal control over financial reporting
that occurred during the quarter that has materially affected or that is
reasonably likely

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to materially
affect your internal control over financial reporting, as required by Item 208(c) of
Regulation S-K.  In the alternative,
please supplementally confirm to us, if true, that there were no changes in
your internal control over financial reporting that occurred during the quarter
that have materially affected or are reasonably likely to materially affect
your internal control over financial reporting.

SEC Response No. 2.

We hereby
confirm that there were no changes in internal controls over financial
reporting that occurred during the quarter that materially affected or
reasonably likely to affect our internal controls over financial
reporting.  The term “other” should not
have been included in the prior filing.

The Company
hereby acknowledges that:

it is
responsible for the adequacy and accuracy of the disclosure in the Company’s
filings;

staff comments
or changes to disclosure in response to staff comments in the filings reviewed
by the staff 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.

 ********************************************

Please contact
the undersigned at (952) 443-7020 if you have any questions or need
additional information.

Very truly yours,

PPT VISION, INC.

Timothy C. Clayton

cc:                                 Thomas G. Lovett, IV

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