SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      November 23, 2005

Via U.S. Mail and Facsimile

Timothy B. Hansen
Chief Executive Officer
Imaging Diagnostic Systems, Inc.
6531 NW 18th Court
Plantation, Florida 33313

RE:		Imaging Diagnostic Systems, Inc.
		Form 10-K for the Fiscal Year Ended June 30, 2005
		Form 10-Q/A for the Fiscal Quarter Ended March 31, 2005
		Response Letter dated October 7, 2005
		File No. 000-26028

Dear Mr. Hansen:

      We have reviewed the above filings and response letter and
have
the following comment.  We have limited our review of your filings
on
Form 10-K and Form 10-Q/A to disclosures relating to your contacts
with countries that have been identified as state sponsors of
terrorism, and will make no further review of the filings.  Our
review with respect to this issue does not preclude further review
by
the Assistant Director group with respect to other issues.  At
this
juncture, we are asking you to provide us with supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. 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
filings.
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.

General -

We note the representation in your letter that to date you have
sold
no products into Libya or Iran, and that you no longer are party
to a
distribution agreement that provides for sales into Libya.  We
note
also your representation that any future sales of your products
into
Iran will be made in compliance with the laws of the United States
and Florida, as well as applicable Iranian laws.

Finally, we note that you have entered into several distribution
agreements pursuant to which your products may be sold into Iran.
Please discuss for us your view as to the materiality of those
agreements and whether they pose a material investment risk for
your
security holders, notwithstanding that any future sales under the
agreements may be made in compliance with applicable laws, in
light
of the potential impact upon your reputation and share value of
your
status as a party to agreements that contemplate the sale of your
products into a country identified as a state sponsor of terrorism
and subject to U.S. economic sanctions imposed, in part, as a
result
of its sponsorship of international terrorism and active pursuit
of
weapons of mass destruction.  Provide us with both your
conclusions
and underlying analysis.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the 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 the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, 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 filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; 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 filings or in response
to
our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Peggy Fisher
		Assistant Director
		Division of Corporation Finance

</TEXT>
</DOCUMENT>