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CORRESP
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July 28,
2005

VIA EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street N.E.

Washington,
D.C.  20549

  Attention:

  Stephen G. Krikorian, Accounting Branch Chief

  Lisa Mitrovich, Assistant Chief Accountant

  Jason Niethammer

  Re:

  InFocus Corporation

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

  Form 10-Q for Fiscal Quarter Ended March 31, 2005

  File No. 000-18908

Ladies
and Gentlemen:

InFocus
Corporation (“InFocus” the “Company”) is responding via EDGAR to the comments
of the Staff of the Securities and Exchange Commission set forth in the Staff’s
letter dated July 19, 2005 in connection with the Company’s Form 10-K
for the fiscal year ended December 31, 2004, and the Company’s Form 10-Q
for the fiscal quarter ended March 31, 2005.

For
ease of reference by the Staff in reviewing the Company’s responses to each of
the comments and as requested by the Staff, each comment is referred to
separately by the number set forth in the letter from the Staff dated July 19,
2005.

Form 10-K for 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

  COMMENT 1:

  We note that $2.4 million of your income before taxes for 2004
  related to your share of the profitability of Motif, your 50/50 joint venture
  with Motorola.  Explain how you
  considered the disclosure requirements of Rule 4-08(g) of
  Regulation S-X.

  RESPONSE:

  Rule 4-08(g) of Regulation S-X provides guidance on the
  necessity of disclosures related to summarized financial information for 50
  percent or less owned entities accounted for on the equity method by the
  registrant.  The summarized information
  as to assets, liabilities, and results of operations shall be presented in
  the notes to the financial statements of the registrant if the 50 percent or
  less owned entity is considered to be a significant subsidiary as outlined in
  Rule 1-02(w).  In order for an
  entity to meet the significant subsidiary test it must meet one of three
  criteria set forth in Rule 1-02(w).
  InFocus has performed the necessary analysis and determined that Motif
  does not meet any of these three criteria and therefore does not meet the
  significant subsidiary test and does not require disclosure of the summarized
  financial information.  Each of the
  three criteria is described below along with the InFocus response as to why
  Motif does not meet the established criteria for this disclosure.

  The first criteria is that the registrant’s investment in and
  advances to the entity exceed 10 percent of the total assets of the
  registrant’s consolidated balance sheet as of the end of the most recent
  completed fiscal year.  At
  December 31, 2004, the balance of InFocus’ total investment in and
  advances to Motif was $0.3 million compared to InFocus’ total assets at
  December 31, 2004 of $383.9 million.
  The calculation of InFocus’ investment in Motif compared to InFocus’
  total assets is less than 10 percent and InFocus does not meet this criteria.

  The second criteria is that the registrant’s proportionate share of
  the total assets of the entity exceeds 10 percent of total assets of the
  registrant’s consolidated balance sheet as of the end of the most recent
  fiscal year.  At December 31, 2004,
  Motif’s total assets were $1.5 million which made the InFocus share at 50
  percent equal $0.8 million.  InFocus’
  total assets at December 31, 2004 were $383.9 million and therefore the
  InFocus share of Motif’s assets were less than 10 percent of InFocus’ total
  assets and the criteria have not been met.

  The third, and final criteria, is that the registrant’s equity in the
  income from continuing operations before income taxes of the entity exceeds
  10 percent of income from continuing operations before income taxes of the
  registrant’s consolidated income for the most recently completed fiscal
  year.  This criterion is further
  explained in Rule 1.02(w) which guides registrants to use the average of
  income over the last five fiscal years if income for the registrant’s most
  recent fiscal year is at least 10 percent lower than the average income for
  the last five years.  Rule 1.02(w)
  also provides that any loss years should be omitted for the purposes of
  computing average income for the last five years.  InFocus’ net income before income taxes in
  2004 was greater than 10 percent lower than net income before tax (profits
  years only) for the five year average and therefore we used the five year
  average to calculate the requirements of this test.  The InFocus equity in the income from Motif
  in 2004 was $2.4 million which was compared to the average income before
  income taxes for InFocus for the last five years of $37.9 million, excluding
  loss years in 2003 and 2004.  InFocus’
  equity in the income of Motif for 2004 was below the 10% threshold and
  therefore the third criteria was not met.

  Through the analysis discussed above InFocus concluded that it was
  not required to disclose the Motif financial information in the footnotes as
  it did not qualify as a significant subsidiary.

  COMMENT 2:

  We note that “Motif license fees are recognized when licensees report
  sales and resultant royalties, which are currently only contractually
  required on a semi-annual basis.”
  Explain why there is a significant time delay for Motif’s licensees to
  report sales and resultant royalties.
  Explain if and whether Motif’s management has the ability to estimate
  the license revenues prior to receiving the royalty reports. Refer to SAB
  Topic 13A(1).

  RESPONSE:

  SAB Topic 13A(1) states that revenue should not be recognized
  until it has been realized and earned based on a transaction meeting all four
  criteria outlined in SAB Topic 13A(1).
  Motif license fees are recognized at the point all four criteria have
  been met, which has been determined to be at the time the licensees report
  sales and resultant royalties.  Motif
  license fees are derived from licensees selling product containing

  Motif’s licensed technology.
  As a result, Motif’s license revenues are dependant on the number of units
  sold by the licensee.  Motif has
  licensed its technology to 12 licensees and 10 of the contracts call for
  reporting semi annually 60 days after the completion of the six month period
  specified.  The other two contracts
  require royalty reporting quarterly.
  InFocus has determined that criteria number two, which requires
  delivery to have occurred or services to have been rendered, is not met until
  the licensee has submitted a royalty report to Motif.  InFocus has further determined that neither
  InFocus nor Motif management has the ability to develop an estimate that is
  sufficiently reliable to accrue estimated royalties on a consistent
  basis.  InFocus has analyzed the trends
  in revenues from licensees and has determined there is no consistency over
  time (i.e. no linearity) providing a basis for reasonable estimation prior to
  receiving royalty reports from the licensee.
  For the reasons stated above, InFocus and Motif do not recognize
  revenues until the required reporting has been received from licensees.

  Note 1. Summary of Significant Accounting Policies, Revenue
  Recognition, page F-11

  COMMENT 3:

  We note disclosure on page 17 that revenues in 2004 grew, in
  part, as a result of increased royalty revenues.  Please tell us your revenue recognition policy
  for your royalty revenues and explain why you have not disclosed this policy
  in your revenue recognition accounting policy.

  RESPONSE:

  InFocus earns royalty revenues through several contractual agreements
  to license intellectual property.  In
  fiscal year 2003 and 2004 royalty revenues were less than 1.5% of net
  revenues.  However, royalty revenues
  are pure margin and therefore have a larger impact on gross margins.  InFocus determined that it was beneficial
  to discuss royalty revenues as one of the drivers of the revenue increase in
  2004 as compared to 2003 due to the impact on gross margins and the fact that
  royalty revenues dollars grew over 450% from fiscal year 2003 to fiscal year
  2004.  While royalty revenues from 2003
  to 2004 were less than 1.5% of total net revenue in either year, the increase
  in royalty revenues increased reported gross margins by about 1.0%.  InFocus’ revenue recognition policy on
  royalty revenues is consistent with the overall revenue recognition policy
  and revenues are recognized as earned, generally when royalty reports are
  received from licensees.  InFocus did
  not disclose separately the revenue recognition policy on royalty revenues in
  the summary of significant accounting policies in footnote #1 due to the low
  percentage of total revenues.  As
  royalty revenues grow and become a larger portion of net revenue or gross
  margins InFocus will consider disclosing the revenue recognition policy on
  royalty revenues separately.

  Note 7. Income Taxes, page F-19

  COMMENT 4:

  We note your reconciliation between the effective tax rate and the
  statutory federal income tax rate.
  Explain to us the history and nature of the reconciling items labeled
  “Resolution of tax authority items” and “Reduction of tax reserves for
  resolved items.”  Additionally, explain
  how you treated these items, for accounting purposes, in previous periods and
  explain why these items impacted your results for fiscal year 2004 only.  Tell us why you did not provide this
  information in your MD&A given the material impact these items have on
  your effective tax rate.

  RESPONSE:

  Resolution of Tax Authority Items

  The “Resolution of Tax Authority Items” of $0.7 million, or an 11.2%
  impact to our 2004 effective tax rate, relates to refunds received from the
  IRS and Norwegian tax authorities pursuant to favorable conclusions to
  reviews and audits of prior year income tax returns.  In 2004, InFocus completed an Internal
  Revenue Service audit covering the years 1994 through 2002.  As a part of the finalization of the IRS
  audit during 2004, an unclaimed and previously unaccounted for tax refund of
  $0.3 million was paid to InFocus.  In
  Norway, an unclaimed and previously unaccounted for tax refund of $0.4
  million was paid to InFocus during 2004.
  These refunds provided an immediate reduction to income tax expense
  when received during 2004.  InFocus had
  no such items materially impacting tax expense in either 2003 or 2002.

  Reduction of Tax Reserves for Resolved Items

  As part of its quarterly tax provision processes, InFocus reviews its
  tax reserve positions and evaluates if any changes in facts or circumstances
  have occurred that would require the Company to book an increase or decrease
  to its tax reserves.  This quarterly review
  by the Company is completed consistent with SFAS #5 and paragraph 9 in the
  proposed interpretation to SFAS #109 regarding accounting for uncertain tax
  positions.

  The major item included in “Reduction of Tax Reserves for Resolved
  Items” is a Norwegian carry-back refund receivable of $1.6 million that
  became available due to the fourth quarter 2004 closure of InFocus’ Norwegian
  operations and the related elimination of the need for $1.1 million of the
  previously established Norway tax reserves.
  The total impact of the Norwegian closure on our effective tax frate
  for 2004 was 43.8%.

  Based on communications with tax authorities and the status of tax
  audits, InFocus released additional tax reserves during the fourth quarter of
  2004 totaling $1.7 million, or a 28.2% impact on our effective tax rate, as
  the Company determined reserves were no longer required as a result of
  changes in facts and circumstances.

  The net change in the Company’s tax reserves for 2002 and 2003
  reduced its effective tax rate by 0.1% and 0.5%, respectively in each
  year.  These amounts were reported as a
  component of “Other” in the effective tax reconciliation.  InFocus did not separately report these
  amounts due to immateriality.

  MD&A Disclosure

  InFocus reported the following on page 21 of Form 10-K: “Income
  tax benefit of $1.4 million in 2004 primarily relates to a release of
  previously recorded tax reserves that were resolved in the fourth quarter of
  2004, as well as tax refunds recognized as a result of net operating loss
  carry backs in Norway from 2003 and 2004 to 2002, offset by anticipated 2004
  tax expense in certain foreign tax jurisdictions.” This explanation was
  provided to address the reported “Reduction of Tax Reserves for Resolved
  Items” in our effective tax rate reconciliation.  No other specific items in the effective
  tax rate reconciliation were addressed in the MD&A due to the
  immateriality of the amounts.

  Schedule II – Valuation and Qualifying Accounts, page F-29

  COMMENT 5:

  We note your allowance for uncollectible accounts and sales
  allowances of $11.8 million and $10.8 million for fiscal years ending
  December 31, 2003 and 2004,

  respectively.  Reconcile these
  amounts for each fiscal year to the sum of the allowance for uncollectible
  accounts listed on page F-7 and the reserve for sales returns, price
  protection and other rebates on page F-11.  Furthermore, tell us about the contributing
  factors that led to the $4.8 million (55%) decline in your allowance for
  uncollectible accounts between fiscal year 2003 and 2004, as disclosed at the
  top of page F-7.

  RESPONSE:

  Both schedule II on page F-29 and the disclosures on
  pages F-7 and F-11 include amounts related to reserves on education
  credits, government credits, allowance for doubtful accounts, sales returns,
  and price adjustments.  The only
  difference between the amounts reported on schedule II and the amounts
  reported on page F-7 and F-11 is that the sales return reserve is
  reported on a gross basis in schedule II and on a net basis in the
  revenue recognition footnote on page F-11.  The sales returns reserve essentially
  reverses revenue, cost of sales, inventory and accounts receivable and
  InFocus determined that the most meaningful disclosure is provided by
  reporting this reserve on a net (margin impact) basis in the revenue recognition
  footnote on page F-11.  InFocus
  made this point clear by stating that we were reporting the “net” reserve for
  sales returns, price protection, and other rebates on page F-11.  Please see attached schedule for
  further details.

  Schedule II

  support

  Schedule II

  Disclosure F-7 & F-11

  Description

  12/31/2003

  12/31/2004

  12/31/2003

  12/31/2004

  Doubtful
  Accounts

  (8,713,071

  )

  (3,877,262

  )

  (8,713,071

  )

  (3,877,262

  )

  Revenue
  Reserves

  (3,083,000

  )

  (6,936,167

  )

  (3,083,000

  )

  (6,936,167

  )

  Other

  —

  —

  180,097

  —

  Sales
  returns inventory

  —

  —

  902,903

  2,199,775

  (11,796,071

  )

  (10,813,429

  )

  (10,713,071

  )

  (8,613,654

  )

  In the future, InFocus will evaluate whether more meaningful
  disclosure would be provided by reporting the disclosure in F-11 on a gross
  basis as well.

  The second part of comment 5 asks for the contributing factors that
  led to the $4.8 million decline in our allowance for uncollectible accounts
  balance between fiscal year 2003 and 2004, as disclosed at the top of
  page F-7.  The majority of the
  reduction related to a few specific large direct write-offs to the allowance
  due to partial settlements during 2004 of bad debts that were appropriately
  reserved at the end of 2003.  Of the
  $4.8 million reduction in the allowance for the year, $2.0 relates to direct
  write-offs to the allowance in our European entities and $3.1 million relates
  to write-offs in ou