SecProbe.io

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Mail Stop 6010

      May 31, 2005

Mr. Jeffrey M. Soinski
Chief Executive Officer
Specialized Health Products International, Inc.
585 West 500 South
Bountiful, UT 84010

      Re:	Specialized Health Products International, Inc.
Form 10-KSB for the Year Ended December 31, 2004
Form 10-QSB for the Quarter Ended March 31, 2005
		File No. 000-26694

Dear Mr. Soinski:

      We have reviewed your filings 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. 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 information so we may better understand your disclosure.
After
reviewing this information, we may 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 comments 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

Item 6. Management`s Discussion and Analysis or Plan of
Operations,
page 17

Years Ended December 31, 2004 and 2003, page 21

1. On page 22 of your MD&A and in your Forms 8-K dated March 9,
2005
and May 10, 2005, you disclose various non-GAAP financial measures
such as net income (loss) excluding certain items and operating
expenses excluding certain items.  While these types of disclosure
may be helpful in describing same operating results from period to
period, they remove focus from the excluded items.  In this
regard,
we have the following comments:

* Please revise future filings to discuss changes in your GAAP-
based
results, identifying those unique or material transactions or
events
that contributed to the changes.

* Alternatively, if you elect to retain the current disclosures,
revise future filings to comply with the requirements of Item
10(h)
of Regulation S-B relating to non-GAAP financial measures in
documents filed with the Commission, including providing the
reconciliations of the measures to the most directly comparable
GAAP
measures and the appropriate disclosures regarding your use of the
non-GAAP measures.  Refer to Question 8 of the FAQ Regarding the
Use
of Non-GAAP Financial Measures dated June 13, 2003.

* In the Forms 8-K, the discussion of non-GAAP measures is more
prominent than the discussion of the GAAP measures.  Revise future
filings to present, with equal or greater prominence, the GAAP
measures and the related discussions.

Please provide us with a sample of the disclosures you intend to
include in future filings.

Item 8A. Controls and Procedures, page 32

2. We note your disclosure that "the Chief Executive Officer and
Chief Financial Officer concluded that our disclosure controls and
procedures are effective in timely alerting them to material
information relating to that which is required to be included in
our
periodic SEC filings."  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.  Please revise
future filings 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 is fully consistent with the definition of
disclosure controls and procedures contained in Rule 13a-15(e).

3. Please tell us and revise your disclosure in future filings
concerning changes in your internal control over financial
reporting
to indicate whether there was any change to your internal control
over financial reporting during the quarter being reported on that
has materially affected, or that is reasonably likely to
materially
affect, your internal control over financial reporting.  Refer to
Item 308(c) of Regulation S-B.

Consolidated Statements of Operations, page F-5

4. We note that you recorded $1.3 million in patent litigation
expenses in 2003 and recorded a liability for the same amount.  We
note your disclosures on pages 23 and F-8 that the current portion
of
accrued litigation expenses will not require the use of cash to
pay
the liability.  We also note your disclosures on pages 16 and F-16
that the $1.3 million was your estimate of the portion of costs
associated with BD`s suit against Tyco Healthcare and that Tyco
will
withhold against the royalties due to you through 2005, and that
you
are not a party to the patent infringement lawsuit.

* Please tell us why you believe it is appropriate to recognize
expense and a liability for this litigation in accordance with
SFAS
5.  Discuss how you determined the $1.3 million amount, and also
support your conclusion that the liability should be recognized in
2003.

* You state that your obligations relating to this liability will
be
paid through the holdback of up to 50 percent of future royalties.
However, you also disclose the potential that Tyco will be
prohibited
from selling the product, which would impact your future
royalties.
Tell us whether you would have any further obligation to reimburse
Tyco for legal expenses if the royalties are not sufficient to
cover
your obligations due.

* With respect to your disclosure on page 23 that this liability
will
not require the use of cash, please revise future filings to
clarify
that the liability will be reduced or paid through royalties
received
from Tyco / Kendall.

Note 2. Significant Accounting Policies, page F-8

Revenue Recognition, page F-11

5. Please tell us and revise future filings to discuss in further
detail your revenue recognition policy with respect to products
and
royalties.  Discuss any rights of return or other post-shipment
obligations you may have.  With respect to royalties, discuss how
you
determine when the related products have been sold by third
parties.

Note 5. Stock Options, page F-16

6. We note that in 2004, you gave your current directors and
employees holding stock option grants the option to surrender
those
stock options in exchange for an immediate grant of shares of
restricted common stock.  We note that you have recorded a
deferred
compensation charge for the shares of restricted stock, which will
be
amortized over the vesting period of the restricted stock.
However,
it does not appear that you intend to account for the exchange
using
variable accounting.  Tell us how you considered paragraphs 43 and
45-47 of FIN 44 as well as Issues 36(a) and 39(a) of EITF 00-23 in
concluding that variable plan accounting is not required.

* * * * *

      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 information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing includes all information
required under the Securities and Exchange Act of 1934 and that
they
have provided all information investors require for an informed
investment decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Tom Dyer, Staff Accountant, at (202) 551-
3641,
Kevin Vaughn, Reviewing Accountant, at (202) 551-3643 or me at
(202)
551-3327 if you have any questions.

							Sincerely,

							Michele Gohlke
							Branch Chief

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Mr. Jeffrey M. Soinski
Specialized Health Products International, Inc.
May 31, 2005
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