SecProbe.io

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Mail Stop 0306

March 28, 2005

Via Facsimile and U.S. Mail

Mr. Paul A. Kohmescher
Vice President and Chief Financial Officer
Mikron Infrared , Inc.
16 Thornton Road
Oakland, NJ  07436

	Re:	Mikron Infrared, Inc.
		Form 10-KSB for the fiscal year ended October 31, 2004
			Filed January 28, 2005
		Form 10-QSB for the fiscal quarter ended January 31,
2005
		File No. 0-15486

Dear Mr. Kohmescher:

      We have reviewed your response letter dated March 21, 2005
and
have the following additional comments.  Where indicated, we think
you should revise your future filings in response to these
comments.
If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary.  Please be
as
detailed as necessary in your explanation.  In some of our
comments,
we may ask 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
aspects
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-KSB/A as of December 31, 2004 filed March 21, 2005

Item 8A - Controls and Procedures - Page 27

1. We note your response to comment 5, but disagree with some of
the
statements included in that response.  Please note that it is
never
appropriate to qualify your conclusion with respect to the
effectiveness of your disclosure controls and procedures.  Your
disclosure controls and procedures must be either "effective" or
"not
effective;" it is not appropriate to qualify that conclusion with
language such as "subject to the limitations set forth above" or
otherwise.  Please supplementally acknowledge your understanding
of
the foregoing.  In addition, in future filings, please omit the
"to
provide reasonable assurance that" language that currently appears
after the word "effective" in the penultimate paragraph of your
Item
8A disclosures in your amended Form 10-KSB.  While you may, if
desired, state that your disclosure controls and procedures are
effective "at the reasonable assurance level," we do not believe
that
the "to provide reasonable assurance that" language is consistent
with the definition of disclosure controls and procedures set
forth
in Rule 13a-15(e) of the Exchange Act.

2. We note your response to prior comment 7, and your revised
disclosures on page 28 of the Form 10-KSB/A.  We note you continue
to
state that there have been "no changes in [your] disclosure
controls
and procedures..."  Item 308(c) of Regulation S-B requires you to
disclose any changes in internal control over financial reporting
that materially affected, or are reasonably likely to materially
affect, your internal control over financial reporting.  The terms
disclosure controls and procedures and internal control over
financial reporting have two distinct definitions in the Exchange
Act.  Please supplementally tell us whether there were any changes
in
your internal control over financial reporting that materially
affected, or is reasonably likely to materially affect, your
internal
control over financial reporting.  In addition, revise future
filings
to comply with Item 308(c) of Regulation S-B.  Please note this
comment also applies to your Form 10-QSB/A as of January 31, 2005.

* * * * * * * *

      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 with your response 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.  Please understand that we
may have additional comments after reviewing your amendment and
responses to our comments.

      You may contact Kevin Vaughn, Staff Accountant, at (202)
824-
5387 or me at (202) 942-2861 if you have questions regarding these
comments.  In this regard, do not hesitate to contact Daniel
Gordon,
Branch Chief, at (202) 942-2813.

					Sincerely,

					Kate Tillan
					Reviewing Accountant

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Mr. Paul A. Kohmescher
Mikron Infrared, Inc.
March 28, 2005
Page 1

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