SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
VIA FACSIMILE AND U.S. MAIL

                                                     April 14,
2005

Stephen D. Reichenbach
Principal Financial Officer
Flow International Corporation
23500- 64th Avenue South
Kent, Washington 98032

	RE:	Form 10-K/A for the fiscal year ended April 30, 2004
      Form 8-K filed on April 4, 2005
      File No. 0-12448

Dear Mr. Reichenbach:

	We have reviewed your letter dated April 6, 2005 and have the
following comments.  Where indicated, we think you should revise
your
disclosures 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.  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 on any
other
aspect of our review.  Feel free to call us at the phone numbers
listed below.

Comment applicable to your overall filing

1. Where a comment below requests additional disclosures or other
revisions be made, please show us in your supplemental response
what
the revisions will look like.  These revisions should be included
in
your future filings.

FORM 10-K/A FOR THE YEAR ENDED APRIL 30, 2004

Financial Statements

Statements of Operations, page 35

2. We have read your response to comment 2.  You indicated that
the
litigation loss accrual and loss on previously disposed assets
could
have been included in operating income (loss) for the year ended
April 30, 2003.  Given that the notes for which you recorded an
expense of $1.2 million relate to the sale of your products, it
appears this amount should also be included in operating income
(loss).  Please revise your statement of operations to include the
litigation loss accrual, the loss on previously disposed assets
and
the discount on the sale of notes receivable in operating income
(loss) for the year ended April 30, 2003.

FORM 8-K FILED ON APRIL 4, 2005

3. In the transcript of your March 17, 2005 earnings
teleconference,
you indicated that EBITDA was $2.6 million for the quarter and $10
million for the first nine months of fiscal 2005.  If you continue
to
present these non-GAAP financial measures, please provide the
disclosures required by Regulation G.

*    *    *    *

		Please respond to these comments within 10 business
days,
or tell us when you will provide us with a response.  Please
provide
us with a supplemental response letter that keys your responses to
our comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review.  Please file your
supplemental response on EDGAR as a correspondence file.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

      You may contact Ernest Greene, Staff Accountant, at (202)
942-
8091, or in his absence, Nudrat Salik, at (202) 942-7769, if you
have
questions regarding comments on the financial statements and
related
matters.
							Sincerely,

							Rufus Decker
      						Accounting Branch Chief

??

??

??

??

Mr. Stephen Reichenbach
April 14, 2005
Page 1 of 2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>