SecProbe.io

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Mail Stop 0306

      May 11, 2005

VIA U.S. MAIL AND FACSIMILE (651) 484-8941

Dale H. Johnson
Chief Financial Officer
Angeion Corporation
350 Oak Grove Parkway
Saint Paul, Minnesota  55127

	RE:	Angeion Corporation
		Form 10-KSB for the fiscal year ended October 31, 2004
		Filed January 31, 2005
		File No. 001-13543

Dear Mr. Johnson:

      We have reviewed your response dated April 26, 2005 and
related
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 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-KSB for the year ended October 31, 2004

(13) Discontinued Operations - Page 43

1. We note your response to comment 9.  It remains unclear to us
why
it is appropriate to record the contingent gain for amounts
recoverable from product liability insurance for the ELA Medical
litigation.  Question 5 of SAB Topic 5Y states that "The staff
believes there is a rebuttable presumption that no asset should be
recognized for a claim for recovery from a party that is asserting
that it is not liable to indemnify the registrant."  Registrants
that
overcome that presumption should disclose the amount of recorded
recoveries that are being contested and discuss the reasons for
concluding that the amounts are probable of recovery.  Tell us why
you believe that the recovery is probable and you can confirm the
acquisition of an asset from the insurance company when the
outcome
is dependent on a decision by the court or a compromise among the
parties in a settlement agreement.  Additionally, tell us whether
the
entire balance of assets of discontinued operations relates to the
contingent gain at October 31, 2004 and how you determined a
reasonable estimate of the amount to be recovered.
Form 10-Q for the quarter ended January 31, 2005

Item 3. Controls and Procedures - Page 15
2. We note your revised disclosure in response to comment 11.  You
have included a statement that the principal executive officer and
principal financial officer have concluded that the company`s
disclosure controls and procedures are effective "subject to the
disclosure in the next paragraph."  Given the exceptions noted, it
remains unclear whether your chief executive officer and chief
financial officer have concluded that your disclosure controls and
procedures are effective at the end of the period covered by the
report.  Please revise your disclosure to state, in clear and
unqualified language, the conclusions reached by your chief
executive
officer and your chief financial officer on the effectiveness of
your
disclosure controls and procedures.  For example, if true, you can
state that your disclosure controls and procedures are effective
including consideration of the identified matters, so long as you
provide appropriate disclosure explaining how the disclosure
controls
and procedures were determined to be effective in light of the
identified matters.  Or, if true, you can state that given the
identified matters, your disclosure controls and procedures are
not
effective.  You should not, however, state the conclusion in your
current disclosure, which appears to state that your disclosure
controls and procedures are effective except to the extent they
are
not effective.

*    *    *    *

      As appropriate, please amend your Form 10-Q for the quarter
ended January 31, 2005 and 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 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 responses to our
comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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 Kristin Lochhead, Staff Accountant, at (202) 942-
8972
or me at (202) 942-1791 if you have any questions.

							Sincerely,

							Brian Cascio
							Accounting Branch Chief
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Mr. Johnson
Angeion Corporation
May 11, 2005
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