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CORRESP
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     CORRESP

YIGAL ARNON & CO.

ADVOCATES AND NOTARY

     Tel Aviv
     August 22, 2005

     Ref.
     8116 (5)

     Direct Dial:
     +972-3-608-7864

     Direct Fax:
     +972-3-608-7714

     E-mail:
     adrian@arnon.co.il

Filed with Edgar

Mr. Martin F. James

Securities and Exchange Commission

450 Fifth Street N.W.

Washington, D.C. 20549

Re: RoboGroup T.E.K. Ltd.

Form 20-F for the year ended December 31, 2004 (the "Annual Report")

Filed June 30, 2005

File No. 0-19435

 Dear Mr. James:

        On
behalf of  RoboGroup  T.E.K.  Ltd.,  an  Israeli  Company  (the  "Company"),  set forth
 below are the  Company's  responses to the comments  (the  "Comments")  of the staff of
the  Division of  Corporation  Finance (the  "Staff") transmitted by letter dated August
15, 2005 (the "Comment Letter").

        For
the  convenience  of the Staff,  we have  restated in this letter each of the Comments in
the Comment  Letter and numbered each of the responses to correspond with the numbers of
the Comments in the Comment Letter.

Form 20-F for the year ended December 31, 2004

Consolidated Financial Statements

Independent Auditor's Report, page F-2

1.
    We
see that your auditors' report relies on the audit reports issued by other
independent public accountants for certain consolidated subsidiaries as of and of
each of the three years in the period ended December 31, 2004. Please amend your Form
20-F to include the reports of the other accountants as required by Rule 2-05 of
Regulation S-X.

YIGAL ARNON & CO.

Response: The
Company  advises the Staff that it has added the required  disclosure at pages F-2a and
F-2b            of the financial statements for the Company for the year ended December
31, 2004 included in Amendment No. 1 to the Company's Annual Report on Form 20-F/A.

        Note
1 - General, page F-10

2.
    We
note that you have significantly reduced the activity of MemCall and that
beginning in 2004, the subsidiary has become operationally inactive. Until 2003,
MemCall was accounted for as an individual business sector. Tell us how you
considered whether MemCall should be reported as a discounted operation under
paragraphs 41-44 of SFAS 144 for U.S. GAAP purposes.

Response:

        As
mentioned in Note 6B to the financial  statements,  the activities of MemCall were
 significantly            reduced in the year ended December 2004.

        However,
 the Company  considered  that MemCall should not be reported as a  discontinued
 operation            since there was no  intention to totally (or almost totally)
 dispose of the  activities.  The reasons for the            manner of reporting  MemCall's
 operations  in the  Company's  financials  for the year ended  December 31,
           2004, were that  MemCall continued  its efforts to attract strategic partners
as well as potential customers            for its  products.  In this  context,  MemCall
 searched for  alternative  ways to implement  solutions required by potential  customers.  The Company  considered  that a decrease,  even a
serious            decrease,  in the activities of MemCall did not necessarily  indicate a
discontinued  operation when there were            still reasonable  prospects to renew
the activities,  even if under a new framework.  The Company  considered            that
these facts  indicated that condition (b) of parag.  42 of SFAS 144 (i.e. the entity will
not have any            significant  continuing  involvement  in the  operations  of the
 component)  was not met as of December 31            2004, nor as of March 28, 2005.

        The Company advises the Staff that in this regard, it has added additional disclosures to Part A of
Item 4 of Amendment No. 1 to the Company's Annual Report on Form 20-F/A.

        Kindly
 contact the  undersigned  at  +972-3-608-7864,  if you have any  questions  or require
 additional information.

 Very truly yours,

/s/ Adrian Daniels

cc:
Mr.
Hanan Eibushitz, Chief Financial Officer
      Ms. Vicky Zamir-Sharon, Corporate
Attorney and Secretary

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