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July 22, 2005

Craig Wilson

United States Securities and Exchange Commission

Room 4561

Washington D.C. 20549

RE: Identix Form 10-K for the Year Ended June 30, 2004 and Form 10-Q for the Quarter Ended March 31, 2005.

Dear Mr. Wilson:

On behalf of Identix Incorporated (Identix, the Company, or Our), this letter is in reply to your comment letter
dated June 27, 2005, with respect to the above mentioned Form 10-K and Form 10-Q. Our responses
are set forth below following the text of each comment contained in your letter.

Form 10-K for the Year Ended June 30, 2004

Note 1 — The Company and its Significant Accounting Policies, Page 51

Revenue Recognition, Page 51

SEC Staff comment 1

Tell us the nature and terms of your arrangements with OEM’s and distribution partners. You
disclose on page 22 that not all relationships with these partners are formalized in written
agreements and those that are formalized are often terminable. Tell us how you have considered the
lack of a formal agreement, or if there is an agreement, the fact that it is cancelable, when you
record revenue from OEM’s and distribution partners. Additionally, tell us about any return, price
protection, rotation or similar rights you offer to these customers and explain how your revenue
recognition policies reflect any such rights.

Identix response

Identix commonly sells or licenses its products to systems integrators, OEM resellers or
distributors who in turn resell its products to the end users. Whenever possible, Identix
endeavors to formalize these sales and licensing arrangements with these partners in a master
agreement. In all cases it is Identix’s policy to have written terms and conditions as evidence of
an arrangement in either the form of a detailed contract and/or a purchase order (containing terms
and conditions) issued by the customer (in customary form) and accepted by Identix. Identix will
revise the language for this disclosure in future filings to state, “Evidence of the arrangements
consists of formal written agreements and/or customer purchase orders that contain the terms and
conditions of the sale”.

Certain contracts with distributors have a termination clause that allows the customer to cancel a
contract with or without notice. Under a termination clause the customer remains legally obligated
to pay for product already shipped under the contract, despite any termination for convenience.
There has not been a cancellation of a contract during the three years presented in the Identix
Form 10-K for the year ending June 30, 2004. The Company will continue to monitor cancellations,
if any, in the future to ensure the appropriate accounting treatment is considered. To date, the
contracts and purchase orders the Company has entered into have not provide for any
price protection or stock rotation rights. In addition, the Company is not aware of any
distributors who carry Identix product as inventory.

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SEC Staff comment 2

We note that revenue from sales via third party sales channels are recognized at the time the risks
and rewards are transferred. Tell us how you determine when the risks and rewards are transferred.
Do your sales arrangements specifically identify when risks and rewards are transferred? As part
of your response tell us the amount of revenue recognized from sales to these third parties during
each year presented. Additionally, cite the authoritative literature that supports your accounting
for revenue received from these parties.

Identix response

In a typical third party transaction, the arrangement consists of Identix selling certain hardware,
certain software, or hardware and installation services to the third party. For sales where
Identix is only obligated to ship the product to the customer, the risks and rewards pass at the
time of title transfer at which point revenue is recorded. The point where the customer takes
title to the goods is governed by the evidence of the arrangement. Typically the title passes upon
delivery to a common carrier (FOB shipping point or Ex Works shipping point for international
transactions) but on occasion, depending on the customer and the arrangement, title may pass upon
delivery to the customer (FOB destination). This position is supported by the guidance in Section
3 of Staff Accounting Bulletin (SAB) 104, Revenue Recognition. For the quarter ended March 31,
2005, the Company revised the wording of its revenue recognition policy disclosure in its Form 10-Q
to state the following: “Revenues from sales of products via authorized representatives, dealers,
distributors or other third party sales channels are recognized at the time of title transfer,
generally upon shipment.”

For sales of the Company’s TouchPrint Live Scan Systems where Identix is contracted to install the
hardware systems for the customer, even though the title may pass to the customer at the time of
shipment, Identix does not record revenue until the product is installed and customer acceptance is
obtained because the risk and rewards of ownership do not pass until the customer is required to
pay which occurs upon final installation, receipt of formal written acceptance and issuance of an
invoice to the customer. This position is supported by SAB 104. For the quarter ended March 31,
2005, the Company revised the wording of its revenue recognition policy disclosure in its Form 10-Q
to state the following: “Revenue related to equipment sales that are contingent on installation is
deferred until installation is complete, title has transferred and customer acceptance has been
obtained. Due to current Company policy and practices, the Company considers acceptance of the
TouchPrint Live Scan Systems contingent upon successful installation of the product.”

For the twelve months ended June 30, 2004 and 2003, product sales to third party integrators and
distributors totaled $8,700,000 and $3,120,000 respectively. Immediately following the merger
between Identix and Visionics the Company migrated off the former Identix financial system and as a
result it would be impracticable to obtain this information for fiscal year ended June 30, 2002.

SEC Staff comment 3

We note that you enter into multiple-element arrangements and account for these arrangements under
EITF 00-21. Tell us about the elements that are included in your multi-element arrangements. For
each element, tell us how you determined whether or not the element was a separate unit and how you
determined objective and reliable evidence of fair value.

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Identix response

For multiple element sales arrangements an evaluation is conducted to determine which authoritative
accounting literature applies. For software arrangements with multiple elements, Identix applies
the guidance of SOP 97-2 and the related SOPs. For nonsoftware arrangements with multiple
deliverables, including the Company’s IBIS products, Identix applies the guidance in SAB 104 and
Emerging Issues Task Force Issue (EITF) 00-21, Accounting for Revenue Arrangements with Multiple
Deliverables. For each multiple element arrangement that does not involve software, the Company
determines if each element is a separate unit of accounting pursuant to EITF 00-21 by ensuring (1)
that the element has stand alone value to the customer, (2) that there is objective evidence of
the fair value for the element and (3) that if the arrangement includes a general right of return
relative to the delivered item, that delivery of the undelivered items is considered probable and
in the control of the Company. The elements in a multiple element arrangement typically consist of
hardware products, including the Company’s livescan devices, IBIS products and services, including
installation, training and maintenance services. To determine the fair value for each hardware
element in an arrangement, the Company relies upon vendor-specific objective evidence of fair value
in the form of the price of the element when sold on a stand alone basis to other customers. If
vendor-specific objective evidence of fair value is not available for hardware elements, the
Company relies upon vendor objective evidence of fair value in the form of competitor pricing of
the same or interchangeable products. To determine the fair value for training and installation
services, the Company relies upon vendor-specific objective evidence of fair value in the form of
the price of the services when sold to other customers on a stand alone basis. To determine the
fair value for maintenance services, the Company relies upon renewal rates as stated in the
contract, or renewal rates charged to other customers for the same maintenance services.

SEC Staff comment 4

With regards to the multiple-element arrangements for which separation of the various elements is
not possible, your revenue recognition policy indicates that revenue from these arrangements is
either spread evenly over the performance or deferred until all elements have been delivered. Tell
us which elements are involved and why you are unable to separate the elements. Also, tell us the
specific factors that determine which revenue recognition pattern you apply. Refer to the
authoritative literature you relied upon in determining the revenue recognition for these
arrangements.

Identix response

To date Identix has not entered into a multiple element agreement in which separation of the
various elements was not possible. The language in the June 30, 2004, Form 10-K discusses what
would happen if the Company was unable to separate the elements into separate units of accounting
and is included for the purpose of giving a reader some insight as to how revenue would be treated
had the separation not been possible. In future filings, the Company will revise its revenue
recognition policy disclosure to state the following: “To date the Company has not entered into a
multiple element arrangement where separation of the various elements was not possible. However,
in the case where separation is not possible for an element, the element may be combined with other
elements and the combined elements would be treated as a single element in determining fair value.
If combination with other elements is not possible, revenue on the entire arrangement may be
deferred until all elements are delivered.”

SEC Staff comment 5

For sales of stand-alone software products, your policy note indicates that you recognize revenue
upon meeting the four criteria set forth in SOP 97-2, which include recognizing revenue when
collectibility is “reasonably assured.” Tell us how your accounting complies with paragraph 8 of
SOP 97-2 where collectibility must be probable.

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Identix response

To determine collectibility for all orders, Identix reviews each customer from a credit risk stand
point and also assesses other factors to judge collectibility such as the customer size, location,
past payment history, current disputes, and the type of customer (i.e. government agency vs.
non-government agency). Examining these factors provides Identix with a reasonable basis for
concluding that collectibility is probable as required by SOP 97-2. In future filings, the Company
will revise its revenue recognition policy disclosure to state the following: “The Company
recognizes revenue on software products when persuasive evidence of an arrangement exists, delivery
has occurred, the vendor’s fee is fixed or determinable, vendor-specific objective evidence of fair
value exists to allocate the total fee to all undelivered elements of the arrangement and
collection is deemed probable.”

SEC Staff comment 6

We note that you derive revenue from training and consulting services. Tell us and disclose how
you are accounting for these services and what consideration you have given towards disclosure of
this revenue recognition policy. To the extent service revenue is material; tell us how you
consider Rules 5-03.1 and 5-03.2 of Regulation S-X with regards to your income statement
presentation.

Identix response

The vast majority of the Company’s service revenue is derived from maintenance contracts where such
revenue is recognized ratably over the life of the service period related to the agreement.
The Company also derives revenue from training and consulting services. Revenue from training and
consulting services is recorded as the services are delivered or performed. In future filings, the
Company will revise its revenue recognition policy disclosure to state the following: “Revenue from
training and consulting services is recognized as the services are delivered or performed.” After
consideration of Rules 5-03.1 and 5-03.2 of Regulation S-X, in the Form 10-Q for the quarter ended
December 31, 2004, the Company began to present, on the face of its income statement, revenues and
cost of revenues from products and services separately. Services revenues consist of revenues from
maintenance, training and consulting services. The Company will continue to present revenues and
cost of revenues from products and services on the face of its income statement in future filings.

SEC Staff comment 7

The Company primarily issues perpetual software licenses to government agencies. These are one
time transactions with low risk of the governmental unit being unable to fulfill its obligation to
pay for the software license per the terms of the contract. We note that your arrangements with
government agencies involve funding arrangements. Tell us how your accounting complies with
paragraph 32 of SOP 97-2.

Identix response

Identix does not sell products or services to a governmental agency where the payment is contingent
upon the approval of the appropriation of funds by a governmental body.

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Note 9 — Goodwill, Page 65

SEC Staff comment 8

We note that you recorded a $154.8 million goodwill impairment charge in the year ended June 30,
2003. It appears that the majority of the goodwill impairment relates to the goodwill that was
recorded in the June 2002 Visionics merger. Tell us about the events and circumstances surrounding
this goodwill impairment, specifically address why such a significant write-off was warranted
during the twelve months subsequent to the acquisition date. Further tell us how you determined
that the remaining goodwill balance at June 30, 2004 was recoverable and not considered impaired.

Identix management response 8

On June 25, 2002, Identix merged with Visionics Corporation and $273.0 million of goodwill was
recorded in connection with the merger. When the merger occurred, there was an expectation by the
Company’s management and the markets that the synergies of the combined Company would allow the
Company to operate more efficiently, offer better products and in turn become more competitive and
increase sales. These initial projections were affected by changes in the biometric market place
that occurred in the twelve months following the merger, including:

    1)

    An economic recession that delayed commercial capital spending programs.

    2)

    State and local budgetary deficits that delayed or reduced the level of state
and local spending on biometrics.

    3)

    A federal budget deficit and war delayed the roll-out of federal spending
programs.

    4)

    Increased competition in the biometric marketplace that drove a decrease in
gross margins.

These factors combined to significantly change the fair value of the Company and how the
Company was viewed by the investing community. This is evidenced by the decline in the Company’s
stock price from $7.29 at June 30, 2002 to $6.34 at June 30, 2003, and a decrease of approximately
43% in the trailing twelve month enterprise revenue multiple from June 30, 2002 (16.85) to June 30,
2003 (9.68). The previously stated factors resulted in a decrease in management’s estimate of the
Company’s expected future cash flows when comparing expected cash flows at June 30, 2002 to the
expected cash flows at June 30, 2003. This d