SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 4561

				August 19, 2005

C. Kyle Ranson
President and Chief Executive Officer
Infocus Corporation
27700B SW Parkway Avenue
Wilsonville, Oregon 97070

Re:	Form 10-K for Fiscal Year Ended December 31, 2004
		Form 10-Q for Fiscal Quarter Ended March 31, 2005
		Form 10-Q for Fiscal Quarter Ended June 30, 2005
		File No. 000-18908

Dear Mr. Ranson:

	We have reviewed your response letter dated July 28, 2005 and
have the following comment.  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 our comment, 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 comment 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-K for the Fiscal Year Ended December 31, 2004

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Results of Operations, page 17

Other Income (Expense), page 22

Prior Comment No. 1

1. We note the calculation of your average income before income
taxes
for the last five years when calculating the third criteria set
forth
in Rule 1-02(w) of Regulation S-X.  Note that when computing the
average pretax income, any loss years should be assigned a value
of
zero in computing the numerator for this average, but the
denominator
should be 5.  Accordingly, it appears that your equity income from
Motif ($2.4 million) exceeds 10% of your average income before
taxes
for the last five years, and disclosures under Rule 4-08(g) of
Regulation S-X for your Motif investment are required.

       Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please submit all
correspondence and supplemental materials on EDGAR as required by
Rule 101 of Regulation S-T.  You may wish to provide us with
marked
copies of any amendment to expedite our review.  Please furnish a
cover letter with any amendment that keys your response to our
comment and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing any amendment and your
response to our comment.

	You may contact Jason Niethamer at 202-551-3855, Lisa
Mitrovich
(Assistant Chief Accountant) at 202-551-3453 or me at 202-551-3730
if
you have questions regarding the above comment.

Sincerely,

Stephen G. Krikorian
Accounting Branch Chief
??

??

??

??

C. Kyle Ranson
Infocus Corporation
August 19, 2005
Page 1

</TEXT>
</DOCUMENT>