SecProbe.io

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Mail Stop 0306

						June 14, 2005

VIA U.S. MAIL AND FAX (509) 783-5475

Mr. Jon Correio
Chief Financial Officer
Electronic Systems Technology, Inc.
415 North Quay Street
Kennewick, Washington 99336

	Re:	Electronic Systems Technology, Inc.
		Form 10-KSB for the year ended December 31, 2004
		Filed March 28, 2005
		File No. 000-27793

Dear Mr. Correio:

      We have reviewed your response dated May 26, 2005 and have
the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents. In our comments, we asked you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	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 comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-KSB for the year ended December 31, 2004

Financial Statements

Note 1. Organization and Summary of Significant Accounting
Policies,
page 8

Revenue Recognition, page 9

1. Please refer to prior comment 6. Provide us with an analysis
that
explains your revenue recognition practices and demonstrates that
your policies are SAB 104 and SFAS 48 compliant, as previously
requested.

Form 10-QSB for the quarter period ended March 31, 2005

Statement of Income (Loss), page 3

2. Please refer to prior comment 8. We note that your engineering
services and support expenses relate to income and expenses
derived
from direct on-site engineering assistance to customers related to
the products you sell. You classify these amounts as non-operating
because the amounts have been relatively low and of a different
nature than your product sales.  We believe you should classify
these
amounts within income from operations since the amounts relate to
your operating activities.  You may state revenues and related
costs
of revenues related to services as a separate line item on the
face
of your statement of operations, if you prefer.

Please provide us with a schedule showing the impact of the
reclassification by fiscal year, including the impact on your
gross
margins.  If you do not agree a reclassification is appropriate,
please tell us in detail the basis for your conclusion.  Refer to
Rule 5-03 of Regulation S-X in your response.

*    *    *    *

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

      You may contact Julie Sherman, Staff Accountant, at (202)
551-
3640, or me at (202) 551-3554 if you have questions.

							Sincerely,

							Angela Crane
							Branch Chief
Mr. John Correio
Electronic Systems Technology Inc.
June 14, 2005
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