SecProbe.io

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Mail Stop 6010

June 13, 2005

Via Facsimile and U.S. Mail

Ms. Kimiko Milheim
Chief Financial Officer
Logic Devices Incorporated
395 West Java Drive
Sunnyvale, CA 94089

	Re: 	Logic Devices Incorporated
		Form 10-K for the fiscal year ended September 30, 2004
      SEC File No. 0-17187

Dear Ms. Milheim:

      We have reviewed your response letters dated April 14, 2005
and
May 17, 2005 and have the following additional comments.  We have
limited our review to those issues we have addressed in our
comments.
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 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-K for the Fiscal Year Ended September 30, 2004

Financial Statements, page 22

Inventories, page 29

1. Please refer to prior comments 1(a) and (c).  Please provide us
with a revised rollforward of your inventory reserve account for
fiscal 2002, 2003, and 2004.  The revised schedule should reflect
the
following amounts: balance at beginning of period, amounts
charged/debited to cost of sales to increase the inventory
reserve,
amounts deducted from the reserve account for inventory that was
sold, amounts deducted from the reserve for inventory that was
scrapped, amounts credited to cost of sales to reduce the
inventory
reserve, other charges/debits, other credits, and the balance at
the
end of the period.  Provide footnotes to explain the nature of
each
significant amount.
2. Please refer to prior comments 1(a) and (c).  Tell us why the
write-off of work-in-process inventory of $250,300 in 2004 and
$1.1
million in 2003 is reflected in your inventory rollforward
schedule
on page 43 as deductions.  Tell us the nature of these write-offs,
the status of the inventory, and whether or not the inventory had
been previously reserved.  Explain how you account for your
inventory
reserves.  Tell us why the amount of deductions shown in the
schedule
on page 43 impacts your costs of sales and gross profit for 2004
and
2003.
3. Please refer to prior comment 1(a) and (d).  Please tell us the
debits and credits recorded in fiscal 2004, 2003, and 2002 to
directly write-off inventory.  Explain how you derived an actual
reserve of $1,043,200 in fiscal 2003 per your response and how
that
amount reconciles with your inventory reserve rollforward on page
43.
Explain why the write-off of inventory results in a decrease to
the
amount of your inventory reserve charged to cost of sales.

*    *    *    *

      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 that keys your response 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 response to our comment.

      You may contact Heather Tress, Staff Accountant, at (202)
551-
3624 or me at (202) 551-3604 if you have questions regarding
comments
on the financial statements and related matters.  In this regard,
do
not hesitate to contact Michele Gohlke, Accounting Branch Chief,
at
(202) 551-3327.

Sincerely,

Kate Tillan
Assistant Chief Accountant

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Ms. Kimiko Milheim
Logic Devices Incorporated
June 13, 2005
Page 3

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