SecProbe.io

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				May 25, 2005

Michael Horan
President and Chief Executive Officer
Dynatem, Inc.
23263 Madero, Suite C
Mission Viejo, CA  92691

RE:	Dynatem, Inc.
	Form 10-KSB for fiscal year ended May 31, 2004
	File No. 000-16250

Dear Mr. Horan:

      We have reviewed the above referenced filing and have the
following comment.  Please note that we have limited the scope of
our
review to only your financial statements and related disclosures.
Where indicated, we think you should revise your document in
response
to this comment.  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 comments or 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 May 31, 2004

Notes to Financial Statements

Note 1.  Organization and Summary of Significant Accounting
Policies
Revenue Recognition

1. Disclosure on pages 3 and 4 indicates that you derive revenues
from a variety of sources, including the sale of CPU boards,
systems
and software, software drivers, support services, hardware,
distribution of Microsys products, resale of other manufacturer`s
software and the sale of custom-designed products and software.
Supplementally describe your revenue recognition policy for each
type
of product and service that you sell.  Clearly indicate the timing
and measurement of revenue from each type of earnings activity.
Identify the elements included in each type of sales transaction
(e.g. software, products, hardware, customization services and
post-
contract customer support).  Describe how you`ve considered the
guidance in SOP 97-2 for recognizing revenue from the sale of
software and EITF 00-21 in accounting for multiple-element
arrangements.  With respect to the distribution of Microsys
products,
describe how you have considered the guidance in EITF 99-19.

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 April Coleman at (202) 551-3458 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 or me at (202)
551-3730 if you have questions regarding these comments.

Very truly yours,

      Craig Wilson
							Senior Assistant Chief
Accountant
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Dynatem, Inc.
May 25, 2005
Page 1 of 3

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