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October 11, 2005

  Ms. Kathleen
  Collins

  Accounting
  Branch Chief

  Securities
  and Exchange Commission

  100 F
  Street, N.E.

  Washington,
  D.C. 20002

  Fax: 202-772-9208

Dear
Ms. Collins:

On behalf of Ciprico Inc., this letter responds to
the comments received from you on behalf of the Securities and Exchange
Commission in a letter dated September 29, 2005.  We are fully committed to being compliant
with SEC regulations and in providing the public the appropriate information on
which they base their investment decisions.

  In
response to your letter we provide the following explanations and commentary as
to why we feel no revision to our filings is necessary at this time.  We believe our disclosure is compliant with
requirements, and is also within the spirit of the regulations.  For ease of reference the Commission’s
comments appear directly above the Company’s response.

Form 10-K for Fiscal Year Ended September 30,
2004

Notes to the Consolidated Financial Statement

Note 1.
Summary of Significant Accounting Policies

Revenue
Recognition, page 28

1.               Comment:

It is unclear from your response how you are accounting for all the
technical support services you describe on page 8 of your Form 10-K
(including ongoing technical assistance, training and technical support).  Please clarify whether each of these services
are only a component of the separate service contract the customer chooses to
enter into or whether they are part of the standard warranty you provide.  As previously requested, refer to EITF 00-21
to support your accounting for these multiple elements, clearly indicating how
you allocate fees to each deliverable in your arrangement.

Response:

We apologize for any confusion the wording in
the Form 10-K implies and will certainly work toward clarity in future
filings.

Our products are sold with only a warranty
and no other service components.  Revenue
is recognized upon shipment of the product and warranty cost is accrued

based on estimated costs to
provide such warranty given historical experience and expectation of future
conditions.  Again, no other technical
services are sold as part of the product sale.
Therefore we do not believe there is a multiple element sale nor do we
believe EITF 00-21 applies.

The first paragraph under the sub-heading “Technical
Support” on page 8 of the Form 10-K discusses the components of our
various service contracts (contract terms used are “Hot Spares”, “24/7 phone
support” and “On-site support”).  These
service contracts are sold to our customers independently of the product
sale.  The second paragraph focuses on
the standard warranty we provide with a product sale.  The second paragraph also alludes to the
opportunity for extended warranty and maintenance services (we do not use these
as defined contract terms) which actually refer back again to service
contracts.  We account for the extended
warranty and maintenance services in conformity with FASB Technical Bulletin No. 90-1.

Our handling and accounting for service
contracts is described and disclosed in Item 7, page 19 of Form 10-K
as well as Note 1 of the Notes to the Consolidated Financial Statements on page 28
of Form 10-K where we state:  “Revenue from extended warranty and maintenance
agreements is recognized on the straight-line basis over the term of the
agreement”.

To summarize:
we sell service contracts to a small number of customers and thus all revenue
from these arrangements represents only approximately 3% of revenues.   The sale of our products is not a multiple
deliverable sale as the only undelivered item is warranty, which is covered
under higher-level literature and for which our accounting treatment is
appropriately disclosed.  Future filings
will clarify the delineation between warranty and service.

2.               Comment:

In future filings, revise your discussion of Technical Support in your Form 10-K
to indicate that this only represents approximately 3% of your revenues.

Response:

As noted in your comment we will make such
indication

Form 8-K/A filed March 30, 2005

Item 9.01 Financial Statements and Exhibits

(a) Financial Statements of Businesses
Acquired, page 2

3.               Comment:

As previously indicated, you should include contingent consideration in
the test of your investment’s significance unless the likelihood of its payment
is remote.  Please clarify whether, at
the time of the acquisition, payment of $3.3 million in contingent
consideration, which appears to have been excluded in your significance
calculation, was remote.  If so, ensure
disclosure to that effect is included in your disclosures surrounding your
acquisition of Huge Systems.  If not,
than provide the financial statements required by Rule 3-05 of Regulation
S-X.

Response:

We need some
clarification of the above comment as in our response dated June 16, 2005
(in response to your June 2, 2005 letter) we indicated we had included
$1.2 million of contingent consideration in the test of significance.  We do not recognize the above reference to a
$3.3 million amount.

As noted in
the documents filed the maximum amount of contingent payment that could be paid
is $4.5 million.  The likelihood of
payment of the $4.5 million at the time of filing was (and remains)
remote.  To meet the disclosure requirements
(20% of the assets of Ciprico) a contingent consideration amount of approximately
$3.4 million would need to be considered.
As with the $4.5 million amount, we believe the likelihood of payment of
$3.4 million at the time of filing was (and remains) remote.

As defined in
the Asset Purchase Agreement (filed with the Form 8-K) the contingent
consideration is dependent on the amount of Gross Profit generated from the
product line purchased.  The best
estimate at the time was that the contingent consideration would be
approximately $1.2 million.  At the time
of filing of the above referenced From 8-K/A as well at the time of the Form 10-Q
filing for the quarter ended March 31, 2005, there was not enough support
to accrue an amount that would be paid “beyond a reasonable doubt”.

4.               Comment:

We note disclosure in your June 30, 2005 Form 10-Q that you
recorded a payable for the contingent consideration of $1.0 million based on
performance of the business.  Tell us how
your accounting for this contingent consideration complies with paragraphs 26
and 27 of SFAS 141.  In this regard, clarify
why you believe the outcome of the contingency is determinable beyond a
reasonable doubt, particularly in light of your statements in your response to
prior comment no. 5 that indicate the contingent consideration will most likely
be ‘substantially less’ than $1.2 million.

Response:

Based on
substantial sales increases in the Huge Systems products through June, as well
as sales activity and orders in July, it was clear beyond a reasonable doubt
that some amount of contingent consideration would be paid.  In support of this is the fact payment under
the contingent consideration arrangement was made at the end of July, as
disclosed.  Thus in compliance with
paragraphs 26 and 27 of SFAS 141 we determined that total contingent
consideration of approximately $1 million would be paid and should be accrued
as of June 30, 2005.  By the very
nature of such contingent arrangements the facts change and the impacts of
sales activity make the assessment a dynamic activity.  At the time of our earlier response we did
not have the advantage of seeing the June & July sales order
activity.  Even if we did have that
knowledge, we would still consider the $1 million amount as “substantially less”
than the earlier $1.2 million estimate.
There is no question that the assessment of what will be paid in
contingent consideration beyond a reasonable doubt will require reassessment
for our next filing (Form 10-K) as we gather more historical data (actual
shipments and order

activity) and get closer to the end of the 12
month period on which the contingent consideration calculation is based.

We are available and willing to discuss any of these items with members
of your staff.  My direct line is 763-551-4016.

Regards,

  /s/ Monte S. Johnson

Monte S. Johnson

Vice President – Finance & Chief Financial Officer

Cc:                               Mr. James
W. Hansen, Chief Executive Officer