SecProbe.io

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[LOGO] MIKRON
       INFRARED

March 21, 2005

Mr. Kevin L. Vaughn
Staff Accountant
Securities and Exchange Commission
Washington, D.C. 20549

Re:   Mikron Infrared, Inc.
      Form 10-KSB for the fiscal year ended October 31, 2004
      Form 10-QSB for the fiscal quarter ended January 31, 2005
      File # 0-15486

Dear Mr. Vaughn,

I have set forth below, our responses to the points raised in Ms. Tillan's
letter dated March 9, 2005 regarding our above-referenced filings.

Item 6. Management's Discussion and Analysis of Financial Condition and Results
of Operations

Liquidity and Capital Resources-Page 23

      1.    Comment: We note your table of contractual obligations and
            commitments on page 24. This information appears similar to the
            information required by Item 303(a) (5) of Regulation S-K, but does
            not include all of the information required by that item. Please
            tell us why you included this information in your Form 10-KSB. If
            the information was provided voluntarily, please revise future
            filings where you include this information to be consistent with all
            the requirements of Item 303(a)(5) of Regulation S-K since to do
            otherwise may be confusing.

            Response: We provided this information on a voluntarily basis. In
            the event that we do so again in the future, we will provide this
            information in accordance with all of the requirements of Item 303
            (a) (5) of Regulation S-K.

Critical Accounting Estimates-Page 25

      2.    Comment: We note that you include "some critical areas where
            estimates and assumptions are required." Please respond to the
            following comments:

            (A)   Your disclosure in critical accounting estimates should
                  supplement, but not duplicate, your description of accounting
                  policies in the notes to your financial statements. Your
                  discussion should provide greater insights into the quality
                  and variability of information regarding financial condition
                  and operating performance.

                                               Mikron Infrared, Inc.
                                 16 Thornton Road, Oakland, New Jersey 07436 USA
                                 Telephone: (201) 405-0900 Fax: (201) 405-0090
                                 www.mikroninfrared.com o www.irimaging.com

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Mr. Kevin Vaughn
March 21, 2005
Page 2

            Response: Our future filings will conform to your comments.

            (B)   Please tell us why you included revenue recognition as a
                  critical area where estimates are required. Please review
                  future filings to explain how you use estimates in determining
                  the amount of revenue to record. Cite the accounting
                  literature upon which you relied.

                  Response: We do not believe revenue recognition is a critical
                  accounting estimate since there are no significant estimates
                  involved in our revenue recognition process. We will delete it
                  in the future.

Item 8A- Controls and procedures-Page 27

      3.    Comment: We note your statement that "any controls and procedures,
            no matter how well designed and operated, can provide only
            reasonable assurance of achieving the desired control objectives,
            and that management must apply its judgment in evaluating the
            cost-benefit relationship of possible controls." Please revise to
            state clearly, if true, that your disclosure controls and procedures
            are designed to provide reasonable assurance of achieving their
            objectives and that your principal executive officer and principal
            financial officer concluded that your disclosure controls and
            procedures are effective at that reasonable assurance level. In the
            alternative, remove the reference to the level of assurance of your
            disclosure controls and procedures. Please refer to Section IIF.4 of
            Management's Reports on Internal Control Over Financial Reporting
            and Certification of Disclosure in Exchange Act Periodic Reports,
            SEC Release No. 33-8238, available on our website at
            http://www.sec.gov/rules/final/33-8238.htm. Please note this comment
            also applies to your January 31, 2005 Form 10-QSB.

            Response: We have revised our Controls and Procedures disclosures to
            conform to this comment, as well as your comments numbered 4, 5, 6
            and 7, and have incorporated those disclosures into amendments to
            our 10-KSB and 10-QSB filings that we have this date filed via
            EDGAR.

      4.    Comment: We note that your statement included in your disclosure
            that management has concluded that your disclosure controls and
            procedures are effective "to ensure that material information
            relating to the Company and its consolidated subsidiary is made
            known to management, which include the CEO and CFO, particularly
            during the period when [your] periodic reports are being prepared,
            and that [your] disclosure controls and procedures are effective to
            provide reasonable assurance that [your] financial statements are
            fairly presented..." The language that is currently included after
            the word "effective" in your disclosure appears to be superfluous,
            since the meaning of "disclosure controls and procedures" is
            established by Rule 13a-15(e) of the Exchange Act and is also
            separately presented in your Item 8A. Please revise to limit your
            conclusion to state simply whether the disclosure controls and
            procedures were effective. However, if you elect to retain
            qualifying language in your disclosure, revise so that the language

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Mr. Kevin Vaughn
March 21, 2005
Page 3

            is fully consistent with the definition of disclosure controls and
            procedures contained in Rule 13a-15(e). In this regard, please note
            that the term "reasonable assurance" does not appear in the
            definition of disclosure controls and procedures as set forth in the
            rule. Please note this comment also applies to your January 31, 2005
            Form 10-QSB.

            Response: The reference to "its consolidated subsidiary" should have
            read, and has been corrected in the 10-KSB and 10-QSB amendments to
            read "its consolidated subsidiaries." Also, as noted in our response
            to Comment 3, the amendments to our 10-KSB and 10-QSB filings
            conform to your comments.

      5.    Comment: We note that your statement that "[your] CEO and CFO have
            concluded that, subject to the limitations described above, [your]
            disclosure controls and procedures are effective...". Because your
            statement contains the phrase "subject to the limitations above," it
            does not appear that your certifying officers have reached an
            unqualified conclusion that your disclosure controls and procedures
            are effective. Please revise to address your officers' conclusions
            regarding the effectiveness of your disclosure controls and
            procedures. Please note this comment also applies to your January
            31, 2005 Form 10-QSB.

            Response: We do not completely agree that it is necessary to state
            an unqualified conclusion that our disclosure controls and
            procedures are effective. However, we have concluded that we did not
            state a sufficient basis for qualifying the conclusions contained in
            our Controls and Procedures disclosures. Accordingly, the
            disclosures regarding our Controls and Procedures contained in our
            filed 10-KSB and 10-QSB amendments do not contain any qualifications
            regarding the effectiveness thereof. We will continue to make
            unqualified disclosures in that regard in our future 10-KSB and
            10-QSB filings, unless and until we determine that we have, and have
            articulated, sufficient bases to qualify our conclusions.

      6.    Comment: We note that your statement that "[b]ased upon that
            evaluation ... material information relating to the Company and its
            consolidated subsidiary..." On page F7 you refer to the Company
            together with its direct and indirect wholly-owned subsidiaries. It
            does not appear that you conclusion includes all consolidated
            entities. As such, it appears that your certifying officers have
            reached an unqualified conclusion that your disclosure controls and
            procedures are effective. Please revise to address your officers'
            conclusions regarding the effectiveness of your disclosure controls
            and procedures. Please note this comment also applies to your
            January 31, 2005 Form 10-QSB.

            Response: We have read this comment as though you meant to say "it
            appears that your certifying officers have [not] reached an
            unqualified conclusion that your disclosure controls and procedures
            are effective." Assuming we are correct in that regard, please note
            our response to Comment 4. Also, as noted in our response to Comment

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Mr. Kevin Vaughn
March 21, 2005
Page 4

            3, the amendments to our 10-KSB and 10-QSB filings conform to your
            comments.

      7.    Comment: We note that your disclosure that "[t]here have been no
            significant changes in [your]disclosure controls and procedures or
            in other factors that could significantly affect them during the
            fourth quarter of 2004" [emphasis added]' Please revise your
            disclosure as follows:

            (A)   Comment: Under Item 308(c) of Regulation S-B, you are required
                  to disclose any change in your internal control over financial
                  reporting identified in connection with the evaluation
                  required by Rule 13a-15 or 15d-15 that occurred during your
                  last fiscal quarter that has materially affected, or is
                  reasonably likely to materially affect, your internal control
                  over financial reporting. Your current disclosure only refers
                  to disclosure controls and procedures. As such, you should
                  amend your filings to provide the required disclosure under
                  Item 308(c) of Regulation S-B.

                  Response: The amendments to our 10-KSB and 10-QSB filings
                  provide the required disclosure under Item 308(c) of
                  Regulation S-B.

              (B) Comment: Please ensure the language used in your disclosure
                  concerning changes in your internal control over financial
                  reporting indicates whether there was any change to your
                  internal control over financial reporting that has materially
                  affected or that is reasonably likely to materially affect
                  your internal control over financial reporting, consistent
                  with the language used in Item 308(c) of Regulation S-B.

                  Response: The amendments to our 10-KSB and 10-QSB filings
                  conform in all respects to your comment.

              (C) Comment: Item 308(c) of Regulation S-B requires disclosure of
                  any change that occurred during the quarter that materially
                  affected, or is reasonably likely to materially affect, your
                  internal control over financial reporting and is therefore not
                  limited to changes that could affect your internal control
                  over financial reporting only during the period covered by the
                  report. Please ensure that your disclosure complies.

                  Response: The amendments to our 10-KSB and 10-QSB filings
                  conform in all respects to your comment.

Consolidated Financial Statements-Page F-1

Note 1-Summary of Significant Accounting Policies-Page F-7

      8.    Comment Please tell us and disclose in future filings your policies
            with respect to inventory reserves. We note the disclosure in your

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Mr. Kevin Vaughn
March 21, 2005
Page 5

            critical accounting policies. Considering the increase in your
            inventory balance and the reason therefore as disclosed on page 24,
            address the procedure performed to ensure that any excess or
            obsolete inventory reserves are appropriately provide for as of
            October 31, 2004.

            Response: The inventory increased due to a new product launch and
            increased inventory balances to accommodate increased sales. On a
            quarterly basis, we analyze our inventory based on usage and
            turnover. We believe we have an adequate reserve to cover obsolete
            and excessive inventory. We will make this disclosure in future
            filings.

      9.    Comment: Please tell us and disclose in future filings how you
            consider each of the criteria in SAB Topic 13A in your revenue
            recognition policies and how those criteria apply to your company
            specifically.

            Response:

            o     Persuasive evidence of an arrangement exists - The selling
                  price for the transaction is fixed and documented in the
                  purchase order from the customer. We acknowledge the order via
                  facsimile.

            o     Delivery has occurred - We recognize revenues upon shipment of
                  the product (which is acknowledged via facsimile by Mikron).
                  Once a product is shipped, there are no further performance
                  requirements that must be satisfied by Mikron.

            o     The seller's price to the buyer is fixed or determinable - The
                  selling price for the transaction is fixed and documented in
                  the purchase order from the customer. We acknowledge the order
                  via facsimile.

            o     Collectibility is reasonably assured - We evaluate the credit
                  of customers to whom we consider extending credit and about
                  whom we have concluded that collectibility of the selling
                  price is probable at the time of shipment.

                  In our future filings, we will include more expansive
                  disclosures regarding the foregoing.

      10.   Comment: We note your disclosures on page 3 that you offer one and
            two-year warranties on your product. Supplementally tell us and
            revise future filings to disclose your accounting policies for these
            warranties. In addition, if material, provide the roll forward of
            your warranty liability required by paragraph 14 of FIN 45.

            Response: Our warranty accrual is recorded based on our past history
            of warranty expense. Warranty expenses have historically been
            immaterial. In 2004, warranty expense was less than .05 of a percent

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Mr. Kevin Vaughn
March 21, 2005
Page 6

            (.0005) of sales. If warranty expenses or any other accounting
            estimate becomes material