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EST Response Letter

ESTEEM

Wireless Modems

May 26, 2005

Ms. Angela Crane, Branch Chief

United States Securities and Exchange Commission

450 Fifth Street N.W.

Washington DC 20549

RE: Comments for Electronic Systems Technology Inc Form 10KSB and 10QSB.

Ms. Crane:

We have received and reviewed your comments on Form 10KSB for December 31, 2004, and
Form 10QSB for March 31, 2005 for Electronic Systems Technology Inc. We appreciate your
review of our filed material and value the Commissions input to improve our future filings
and disclosures. Below please find listed the original comments received and our responses
as outlined:

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

Item 8A. Controls and Procedures

  We note your disclosure that your principal executive officer and principal financial
    officer have evaluated your disclosure controls and procedures as of a date within 90 days
    before the filing date of your annual report. Please revise future filings to disclose
    management's conclusion regarding the effectiveness of your disclosure controls and
    procedures as of the end of the period covered by the annual report. Refer to Item
    307 of Regulation S-B and Part III.F of Management's Reports on Internal Control Over
    Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports,
    Release No. 33-8238, available on our website at www.sec.gov/rules/final/33-8238.htm.

  RESPONSE: Future company filings will be revised to disclose
  management’s conclusion regarding the effectiveness of the company’s disclosure
  controls and procedures as of the end of the period covered by the annual report, as is
  required by Item 307 of Regulation S-B, Part III.F of Management's Reports on Internal
  Control Over Financial Reporting, and Certification of Disclosure in Exchange Act Periodic
  Reports, Release No. 33-8238.

  Please also revise your disclosure in future filings to indicate whether there was any
    change in your internal control over financial reporting that occurred during the
    fourth quarter that has materially affected or is reasonable likely to materially
    affect your internal control over financial reporting, as required by Item 308(c) of
    Regulation S-K as amended effective August 13, 2003.

  RESPONSE: Future company filings will be revised to indicate whether
  there was any change in the company’s internal control over financial reporting that
  occurred during the fourth quarter that has materially affected or is reasonable
  likely to materially affect the company’s internal control over financial reporting,
  as required by Item 308(c) of Regulation S-K.

  (EST GRAPHIC)

  Electronic Systems Technology Inc. 415 North Quay St. Kennewick WA 99336 Phone:
  (509)735-9092 Fax: (509)783-5475

  www.esteem.com

  Ms. Angela Crane

  Page 2

  May 26, 2005

  Financial Statements

  Report of Independent Registered Public Accounting Firm

  Please provide us with a copy of the signed audit opinion. Please ensure future filings
    include a properly signed audit opinion from your auditors.

  RESPONSE: Please find attached a signed audit opinion as provided by our
  Auditor, Moe O’Shaughnessy and Associates. The original audit report provided to the
  Company by Moe O’Shaughnessy was officially signed, however in the
  "edgarization" process of the document, the electronic format of the signature
  was inadvertently overlooked. Future company filings will include a properly signed audit
  opinion from the company’s auditors.

  Statement of Income - Page 3

  Revise your statement of income in future filings to separately disclose revenues from
    the sale of product, services, and other products if revenues from any individual
    referenced component are more than 10 percent of the total revenue for the year. Related
    cost and expenses should be combined and disclosed separately as well.

  RESPONSE: As requested, statements of income in future company filings
  will be revised to separately disclose revenues from the sale of products, services, and
  other products for which revenues from any individual referenced revenue component are 10
  percent or more of total revenue for the year. Related cost and expenses for referenced
  revenue components will be combined and disclosed separately also.

  We note your cost of sales on the face of your statement of income includes a
    roll-forward of your inventory. Revise future filings to delete this presentation from
    your income statement or tell us why such presentation is appropriate. Also, confirm that
    all cost of producing finished goods is included in cost of sales. Specifically, tell us
    what is included in "allocated costs?" We may have additional comments after
    reviewing your response.

  RESPONSE: As requested, future company filings will delete the
  roll-forward of inventory presentation on statement of income. To confirm, all costs of
  producing finished goods are included in cost of sales. The term allocated cost is
  comprised of wages and burden, depreciation, repairs/maintenance and professional
  services, specifically and directly related to production.

  Ms. Angela Crane

  Page 3

  May 26, 2005

  Note 1. Organization and Summary of Significant Accounting Policies - Page 8

  Revenue Recognition

  Please expand future filings to describe your revenue recognition policy in greater
    detail. To the extent that the policy differs among customer categories (i.e. domestic MDC
    and foreign industrial automation); make your disclosure product line specific. Details
    should be provided to the extent that policy differs among the various marketing venues
    used by the Company, i.e. distributors and reseller. Also, if the policies vary in
    different parts of the world those differences should be discussed. Provide details of
    discounts, return policies. Post shipment obligation, customer acceptance, warranties,
    credits, rebates, and price protection of similar privileges and how these impact revenue
    recognition. Also provide a supplemental analysis that explains your revenue recognition
    practices and demonstrates that your policies are SAB 104 and SFAS 48 compliant.

  RESPONSE: As requested future company filings will be expanded to discuss
  revenue recognition policies in greater detail, including policy differences for customer
  categories, product lines, geographic location, and resellers of the company’s
  products. Future company filings will also provided details regarding issues such as
  discounts, return policies, post shipment obligations, customer acceptance, warranties,
  credits, rebates, price protection and similar privileges and how these issues impact
  revenue recognition. Future company filings will also provide supplemental analysis
  explaining the company’s revenue recognition practices and demonstrating that the
  policies are SAB 104 and SFAS 48 compliant.

  Note 13. Foreign Sales

  It appears that you have several different operating segments; based on the nature of
    the products that you sell and the types of customers that you have. Please revise future
    filings to clarify your operating segments and revise to comply with the disclosure
    requirement of SFAS 131.

  RESPONSE: Future company filings will be revised to address operating segments and
  compliance with the disclosure requirement of SFAS131.

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

  Statement of Income (Loss)

  Supplementally tell us what is included in the line-item "Engineering
    Services" and Engineering Support" included in your other income (expense)
    total. If this relates to services provided to customers, tell us why it is not included
    in operating income and expense in your statement of income.

  Ms. Angela Crane

  Page 4

  May 26, 2005

  RESPONSE: Engineering Services income is revenue derived from direct, on-site
  engineering assistance for the company’s products contracted from customers, that has
  been invoiced following completion of engineering services by the company. The components
  of engineering services income are items such as engineer labor, travel time and expenses
  (i.e. airline tickets, hotel). Engineering Support expenses are the specific expenses as
  related to engineering service income projects, such as wages paid for on-site engineer
  labor and expenses (i.e. airline tickets, hotel). The Engineering Services (income) and
  Engineering Support (expenses) have not been included in the operating income/expense
  section of the statement of income as historically the income generated from engineering
  services has been relatively low and of a different nature when compared with the
  company’s manufactured products revenues. This segment has also not been included in
  the operating/income expense section of the statement of income as we are of the opinion
  that the low profit margin of the engineering services segment would unusually skew the
  operating income/expense margins of the company’s manufactured products.

  In responding to your comments, we acknowledge that:

  The company is responsible for the adequacy and accuracy of the disclosure in the
  company’s filings;

  Staff comments or changes to disclosure in response to staff comments in the filings
  reviewed by the staff do not foreclose the Commission from taking any action with respect
  to the filing; and

  The company may not assert staff comments as a defense in any proceeding initiated by
  the Commission or any person under the federal securities laws of the United States.

  We look forward to any input and follow up comments that the Commission may have
  regarding our responses to your comments and questions. If you have any questions or need
  additional information, please feel to contact us.

  Sincerely,

  /s/ JON CORREIO
                                                                                      /s/
  T. L. KIRCHNER

  Jon Correio
                                                                                                  Tom
  L. Kirchner

  Vice President, Finance and Administration
                                                   President,
  CEO

  Electronic Systems Technology Inc.
                                                              Electronic
  Systems Technology Inc.