SecProbe.io

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May 6, 2005

Ms. Michele Gohlke
Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington D.C.  20549

Via EDGAR

Re:      ZEVEX International, Inc
         Form 10-K for the Year Ended December 31, 2004 and Related Filings File
         No. 001-12965

Dear Ms. Gohlke:

We have reviewed your letter dated April 26, 2005 relating to the review of
ZEVEX International, Inc. Form 10-K for the Year Ended December 31, 2004 and
Related Filings and provide you with the following responses. In each instance,
we have included your comment and then followed it with our response.

Comment:

Form 10-K for the Year Ended December 31, 2004

Item 9A. Controls and Procedures

1.       We note your disclosure that "Based on that evaluation,  and subject to
         the limitations noted below, our management  concluded that our
         disclosure  controls and procedures are effective to ensure that
         material  information  about us and our subsidiaries is made known to
         management  by others in our company on a timely basis for  preparation
         of our periodic  reports ... we note that  controls and  procedures,
         no matter how well  conceived  and  operated,  can provide  only
         reasonable,  not  absolute, assurance that the objectives of controls
         and procedures are met." Please address the following comments:

<PAGE>

a)                By stating that your conclusion is "subject to the limitations
                  noted below," it does not appear that your management has
                  reached an unqualified conclusion that your controls and
                  procedures are effective. Please revise your disclosure in
                  future filings 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.

b)                The language that is currently: included after the word
                  "effective" in your disclosure appears to be superfluous,
                  since the meaning of "disclosure controls and procedures" is
                  established by Rule 13a-15(e) of the Exchange Act. Please
                  revise future filings to limit your conclusion to state simply
                  whether the disclosure controls and procedures were effective.
                  However, if you elect to retain qualifying language in your
                  disclosure, revise so that the language is fully consistent
                  with the definition of disclosure controls and procedures
                  contained in Rule 13a-15(e).

         c)       Revise future filings to state clearly, if true, that your
                  disclosure controls and procedures are designed to provide
                  reasonable assurance of achieving their objectives and that
                  your principal executive officer and principal financial
                  officer concluded that your disclosure controls and procedures
                  are effective at that reasonable assurance level. In the
                  alternative, remove the reference to the level of assurance of
                  your disclosure controls and procedures. Please refer to
                  Section II.FA of Management's Reports on Internal Control Over
                  Financial Reporting and Certification of Disclosure in
                  Exchange Act Periodic Reports, SEC Release No. 33-8238,
                  available on our website.

2.       We note your disclosure that "there have been no significant changes in
         our internal control over financial reporting during the fourth quarter
         of 2004 or in other factors that could significantly affect those
         controls." Revise future filings to discuss all changes in your
         internal control over financial reporting that have materially
         affected, or that are reasonably likely to materially affect, your
         internal control over financial reporting. Refer to Item 308(c) of
         Regulation S-K.

Response to comments 1.a), 1.b), 1.c) and 2. - Item 9A. Controls and Procedures
of Form  10-K  for the  Year  Ended  December  31, 2004

We acknowledge your comments regarding items 1.a), 1.b), 1.c) and 2., and have
revised our disclosure in future filings beginning with the filing of our Form
10-Q for the Period Ending March 31, 2005 to the following disclosure:

      Our management, including our CEO and CFO, has evaluated the effectiveness
      of our "disclosure controls and procedures" (the disclosure controls and
      other procedures that are designed to provide reasonable assurance that
      for recording, processing, summarizing, and reporting on a timely basis
      the information required to be disclosed in the periodic reports that we
      file with the U.S. Securities and Exchange Commission) as of the end of
      the (Period).

<PAGE>

      The evaluation of our disclosure controls by the CEO and CFO included a
      review of the controls' objectives and design, the operation of the
      controls, and the effect of the controls on the information presented in
      this (Quarterly/Annual) Report. Our management, including the CEO and CFO,
      does not expect that disclosure controls can or will prevent or detect all
      errors and all fraud, if any. A control system, no matter how well
      designed and operated, can provide only reasonable, not absolute,
      assurance that the objectives of the control system are met. Also,
      projections of any evaluation of the disclosure controls and procedures to
      future periods are subject to the risk that the disclosure controls and
      procedures may become inadequate because of changes in conditions, or that
      the degree of compliance with the policies or procedures may deteriorate.

      Based on their review and evaluation as of (Current Period) and subject to
      the inherent limitations as described above, our CEO and CFO have
      concluded that our disclosure controls and procedures (as defined in Rules
      13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934) are
      effective. In addition, they are not aware of any change in our internal
      control over financial reporting during the quarter ended March 31, 2005
      that has materially affected, or is reasonably likely to materially
      affect, our internal control over financial reporting.

Comment:

Consolidated Statement of Operations

3.           We note in Note 2 that you completed the sale of the Physical
             Evaluation segment on December 31, 2003 and recorded a
             non-operating loss of $4.7 million in the fourth quarter of 2003 on
             the disposal. It appears that you sold the business, JTech Medical
             Industries, Inc., to the previous owner, Leonard C. Smith, a former
             employee, officer and director of ZEVEX. Additionally, we note that
             you did not report the operations of the segment as a discontinued
             operation. Please tell us and disclose in future filings the
             following about the transaction:

a)       Discuss whether you have  significant  continuing  involvement in the
         business as defined in EITF 03-13 and paragraph 42 of SFAS 144.

Response to comment 3.a) Consolidated Statement of Operations - significant
continuing involvement

As discussed in footnote 2 to the consolidated financial statements, the Company
had a continuing obligation to deliver certain inventories upon completion of
production. Also, as discussed in footnote 2, the Company may receive additional
payments from JTech based upon specifically identified JTech products sold
during 2004 and 2005. Included as a component of the sale, the Company executed
a manufacturing agreement with JTech, for the production of various component
and finished good products at negotiated prices.

<PAGE>

SFAS 144 paragraph 42, states "The results of operations of a component of an
entity that either has been disposed of or is classified as held for sale shall
be reported in discontinued operations in accordance with paragraph 43 if both
of the following conditions are met: (a) the operations and cash flow of the
component have been (or will be) eliminated from ongoing operations of the
entity as a result of the disposal transaction and (b) the entity will not have
any significant continuing involvement in the operations of the component after
the disposal transaction."

The Company's interpretation of paragraph 42 of SFAS 144, is that the Company
failed to meet the first criterion related to the elimination of cash flow of
the component because of the continuing obligation to manufacture and deliver
certain inventories, the continuing manufacturing agreement, and the potential
to receive payments from the sale of certain JTech products. In considering the
second criterion, the Company considered whether it failed the criterion related
to significant continuing involvement in that it did not believe that it would
have direct "control" over the component of the entity subsequent to disposal.
However, as a result of the continuing manufacturing agreement, the Company
determined that it could be considered to have control indirectly over the
operations of the component due to the significance of the manufacturing process
to the business.  As a result of the conclusions reached regarding both of these
criteria, the Company determined that the disposal should not be classified as a
discontinued operation.

The Company relied only on its interpretation of SFAS 144 at the time of the
disposal because EITF 03-13 was not initiated until late in 2003, was not
finalized until 2004 and its guidance and clarification were not applicable for
disposal transactions until fiscal periods beginning after December 15, 2004.
However, the Company believes that its conclusions would not have changed had
EITF 03-13 been applicable in that paragraph 11.b. discusses that if "The
ongoing entity and the buyer (or the disposed component) are parties to a
contract or otherwise parties to an arrangement that in substance enables the
ongoing entity to exert significant influence over the disposed component's
operating and financial policies.  Judgement is required in evaluating whether
a contract or an arrangement constitutes significant continuing involvement,
and all available information should be considered in performing the related
analysis.   The following factors should be considered in that regard; however,
no one factor should be considered presumptive or determinative: (1)Significance
of the contract or arrangement to the overall operations of the disposed
component..."  As noted above, it appears that the manufacturing agreement,
under EITF 03-13, would also be deemed to constitute significant continuing
involvement in the operations of the disposed component and therefore, the
disposal should not have been classified as a discontinued operation.

Comment:

         b) How you determined the value of the purchase price to be paid by Mr.
Smith.

Response to comment 3.b) Consolidated Statement of Operations - value of the
purchase price

During the evaluation process of refocusing the Company as discussed in our Form
10-K for the Year Ended December 31, 2003, and as further discussed below, in
response to the changing marketplaces of our business segments, we contacted
potential business partners, competitors and business consolidators and
solicited levels of interest in partnering with or purchasing our business
segments, including our Physical Evaluation business segment. The only formal
offer received for our Physical Evaluation business was from Mr. Smith in
December 2003. The offer was negotiated and deemed acceptable by management and
the Board of Directors based on the continued decrease in sales from this
segment, increased sales and marketing expenses, the increased requirement for
research and development investment, and the negative contribution margin of the
business segment.

Comment:

         c) When management made the decision to dispose of the business.

Response to comment 3.c) Consolidated Statement of Operations - managements
decision to dispose of the business

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As stated in our Form 10-K for the Year Ended December 31, 2003, in response to
the changing marketplaces of our business segments, we evaluated our business
opportunities and the need to refocus the Company. During this process, which
began in January 2003 we examined and evaluated various options related to the
divestiture of one or more business segments of the Company, partnering
opportunities, and discontinuation of non-profitable product lines and business
segments. During 2003, the Company contacted numerous companies and discussed
with them potential business opportunities and options related to the various
business segments. It was determined in the middle of the fourth quarter that
the Company would divest itself of the Physical Evaluation Business due to
continued decline in sales, escalating sales and marketing expenses, additional
research and development costs for a new product line, and the negative
contribution margin of the business segment. (See Forms 10-Q for the periods
ending March 31, 2003, June 30, 2003, and September 30, 2003). The Board of
Directors directed management to use its best efforts to complete a transaction
of divestiture by year-end December 31, 2003. All potential business parties
that had been identified in the evaluation process were contacted and asked for
a letter of interest. Mr. Smith was the only party to respond with a letter of
interest outlining terms under which he would entertain the potential purchase
of the Physical Evaluation business segment. Upon notice of this interest the
Company began negotiations with Mr. Smith.

We plan to revise our disclosure in future filings beginning with the filing of
our Form 10-Q for the Period Ending June 30, 2005 to address your comments in
3.a), 3.b), and 3.c) to include statements regarding management's decision to
dispose of the business, determination of the purchase price and to clarify the
obligations of the Company at the time of the sale and in the current period.
The proposed disclosure is the following: (The bracketed and underlined portion
of the disclosure reflect changes from the previous disclosure)

      [During 2003, in response to the changing marketplaces of the Company's
      business segments, the Company evaluated its business opportunities and
      the need to refocus the Company on its core technologies. During this
      process, the Company examined and evaluated various options related to the
      divestiture of one or more business segments of the Company, partnering
      opportunities, and discontinuation of non-profitable product lines and
      business segments. In the fourth quarter of 2003 it was determined that
      the Company would divest itself of the Physical Evaluation business due to
      its continued decline in sales, escalating sales and marketing expenses,
      additional research and development costs of the new product line, and the
      negative contribution margin of the business segment.] On December 31,
      2003, the Company completed the sale of its Physical Evaluation business.
      The transaction was accomplished through the sale of all the issued and
      outstanding capital stock of JTech previously a wholly owned subsidiary of
      the Company. The transaction was effected by a Stock Purchase Agreement
      dated December 31, 2003 by and between the Company and Mr. Leonard C.
      Smith, a former employee, officer and director of the Compan