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September 6, 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

Form 10-Q for Fiscal Quarter Ended June 30, 2005

File No. 000-18908

Ladies
and Gentlemen:

InFocus
Corporation (“InFocus” or the “Company”) is responding via EDGAR to the comment
of the Staff of the Securities and Exchange Commission set forth in the Staff’s
letter dated August 19, 2005 in connection with the Company’s Form 10-K
for the fiscal year ended December 31, 2004, the Company’s Form 10-Q
for the fiscal quarter ended March 31, 2005 and the Company’s Form 10-Q
for the fiscal quarter ended June 30, 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 August19,
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

Prior Comment No. 1

COMMENT 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.

RESPONSE:                       InFocus has evaluated the requirements in Rule 1-02
(w) of Regulation S-X and is in agreement with the conclusion reached by the
staff.  When calculating the average
pretax income as set forth in Rule 1-02(w) of Regulation S-X, any loss
years should be assigned a value of zero in the numerator, but the denominator
should still be set to 5.

In applying this formula to InFocus, the average
income for the last five years, including 5 as the denominator, is equal to
$22.7 million.  The InFocus equity in the
income from Motif in 2004 was $2.4 million, which when compared to the average
income of $22.7 million equates to 10.6% of InFocus average income before
income tax for the five year period.  Since
the result of this calculation exceeds 10%, disclosure under Rule 4-08(g) of
Regulation S-X is required.  This
disclosure requires summarized information related to assets, liabilities, and
results of operations for Motif to be presented in the notes to the financial
statements of InFocus.

The omitted disclosure would appear in the company’s
financial statements as follows:

Motif, Inc

Summarized Balance Sheet
Information at

December 31,

(In thousands)

  2004

  2003

  Current assets (cash)

  $

  1,530

  $

  969

  Noncurrent assets

  —

  —

  Total assets

  1,530

  969

  Current liabilities

  923

  935

  Noncurrent liabilities

  —

  —

  Total liabilities

  $

  923

  $

  935

Summarized Income Statement

Information

(In thousands)

  2004

  2003

  2002

  Revenues

  $

  5,907

  $

  1,456

  $

  464

  Gross Margin

  $

  5,907

  $

  1,456

  $

  464

  Net income

  $

  4,722

  $

  1,236

  $

  290

In determining whether the omission of the
disclosure of the summarized assets, liabilities, and results of operations for
Motif was material in nature, InFocus reviewed SEC Staff Accounting Bulletin No. 99
on materiality.  Staff Accounting
Bulletin No. 99 notes that a matter would be considered material if there
were a substantial likelihood that a reasonable person would consider the
omission important.  Staff Accounting
Bulletin No. 99 also requires review of both quantitative and qualitative
measures when evaluating materiality.  After
reviewing the relevant facts and circumstances, InFocus has concluded that the
omission of the disclosure is not material to its financial statements.

Some of the factors analyzed in evaluating
materiality were Motif’s overall materiality to InFocus as a whole, whether the
omission masked a change in earnings or other trends and whether the omission
impacted multiple years.  As background,
Motif is a standalone intellectual property licensing company with no full time
employees and is not a key component of the overall InFocus business.  In addition, Motif assets, liabilities, and revenues
compared to InFocus assets, liabilities, and revenues are less than 1%.  Lastly, the required disclosure was triggered
only by 2004 results and only by a very small margin.  As a result, InFocus does not believe that
inclusion of the

omitted disclosure would be material to the reader
of the InFocus financial statements when taken as a whole.

In addition, InFocus disclosed the amount included
in other income for the InFocus share of the equity in the earnings of Motif
along with a general description of Motif in the other income(expense) section of
the MD&A for the Form 10-K for Fiscal Year Ended December 31,
2004.

Therefore, InFocus does not plan to amend its Form 10-K
for Fiscal Year Ended December 31, 2004 and will incorporate this
disclosure in its Form 10-K for Fiscal Year Ending December 31, 2005.

In response to the Staff’s
specific request, the Company also acknowledges the following:

•      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 Securities and Exchange Commission from taking any action with
respect to the filing; and

•      The Company may not assert Staff comments as
a defense in a proceeding initiated by the Securities and Exchange Commission
or any person under federal securities laws of the United States.

We
trust you will find the foregoing responsive to the comments of the Staff.  Please direct any questions or comments
regarding this filing to the undersigned at (503) 685-8603.

  Sincerely,

  Mike Yonker

  Executive
  Vice President,

  Chief
  Financial Officer and Secretary

  (Principal Financial Officer)