SecProbe.io

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<FILENAME>filename1.txt
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Mail Stop 6010

August 10, 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
		Filed December 20, 2004
      SEC File No. 0-17187

Dear Ms. Milheim:

      We have reviewed your response letter dated July 26, 2005
and
have the following additional comment.  We have limited our review
to
the issue we have addressed in our comment.  Please be as detailed
as
necessary in your explanation.  In our comment, we ask you to
provide
us with 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 your response to prior comment 1 from our June
13,
2005 letter.  We note that adjustment A in Exhibit A reduces your
inventory reserve in 2002 for lower of cost or market adjustments
or
for excess reserve amounts.  A write-down of inventory to the
lower
of cost or market at the close of a fiscal period creates a new
cost
basis that subsequently cannot be marked up based on changes in
underlying facts and circumstances.  Please tell us the nature of
this decrease to your reserve and discuss your considerations of
the
above and footnote 2 to ARB 43 and SAB Topic 5.BB.

      As appropriate, please respond to this comment 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
August 10, 2005
Page 2

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