SecProbe.io

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

                          SCHLUETER & ASSOCIATES, P. C.
                       1050 Seventeenth Street, Suite 1750
                             Denver, Colorado 80265
                                 (303) 292-3883
                            Facsimile: (303) 296-8880
HENRY F. SCHLUETER
Also Admitted in Wyoming
                                  May 20, 2005

Via Facsimile, EDGAR and U.S. Mail
----------------------------------
Ms. Kristin Lochhead, Staff Accountant
Division of Corporation Finance
United States Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549

     Re: Bonso Electronics International Inc.

Dear Ms. Lochhead:

     We represent Bonso Electronics International Inc. ("Bonso" and "Company").
This letter is in response to your conversation with David Stefanski of
Schlueter & Associates, P.C. on Wednesday, April 27, 2005 in which you requested
that Bonso provide the supplemental analysis as requested in the Commission's
letter dated March 15, 2005 ("Letter"), which relates to the Form 20-F for the
fiscal year ended March 31, 2004, filed on August 13, 2004 with the United
States Securities and Exchange Commission ("SEC"). This response is based upon
information provided to us by Bonso's management in Hong Kong. The responses
below have been numbered to correspond to the numbering used in the Letter.

7.   In future filings please describe the nature of the subsidiaries that are
     included in the "Group." In particular, disclose whether your consolidated
     subsidiaries are wholly owned and whether you hold any subsidiaries that
     are not consolidated. In this regard, please tell us and disclose in future
     fillings whether your wholly owned subsidiary BIL consolidates their
     subsidiary BIL and Bonso Electronics. If not, please provide details of
     your accounting for these subsidiaries.

     Management believes that disclosures with respect to the requested matters
     have been made in note 1 to the Financial Statements and Item 4. in the
     Form 20-F.

     All the consolidated subsidiaries were wholly owned by Bonso except for
     Gram Precision Scales Inc. and its subsidiaries (i.e. Vector Distribution
     Systems Inc., Vector Europe Ltd. and Scale Works Inc.), in which Bonso
     owned 51% of the equity interest. Bonso does not hold any subsidiaries that
     are not consolidated. Further, Bonso's management confirms that Bonso
     Electronics Ltd. ("BEL") consolidated Bonso Investment Limited ("BIL") and
     Bonso Electronics (Shenzhen) Company Limited ("Bonso Electronics") for the
     purpose of preparing the Financial Statements.

<PAGE>

Ms. Kristin Lochhead, Staff Accountant
Division of Corporation Finance
United States Securities and Exchange Commission
May 20, 2005
Page 2

8.   Your disclosure regarding revenue recognition is too vague. Expand future
     filings to describe your revenue recognition policy in greater detail. To
     the extent that policy differs among significant product lines (i.e.
     sensor-based versus wireless products), please make your disclosure product
     line specific. Details should be provided to the extent that policy differs
     among the various marketing venues used by the Company, (i.e. distributors
     and direct sales force.) Also, if the policies vary in different parts of
     the world those differences should be discussed. Provide details of
     discounts, return policies, customer acceptance, warranties, credits,
     rebates, and price protection or similar privileges and how these impact
     revenue recognition. Also provide a supplemental analysis that explains
     your revenue recognition practices and demonstrates that your policies are
     SAB 104 and SFAS 48 compliant.

     In the next filing, the revenue recognition policy will be revised as
     follows:

     "No revenue is recognized unless there is persuasive evidence of an
     arrangement, the price to the buyer is fixed or determinable, delivery has
     occurred and collectibility of the sales price is reasonably assured.
     Revenue is recognized when title and risk of loss transfers to the
     customer, which is generally when the product is shipped to the customer
     from our facility. Shipping costs billed to our customers are included
     within revenue. Associated costs are classified in cost of goods sold.

     The company provides to certain customers an additional two percent of
     certain products ordered in lieu of a warranty, which are recognized as
     cost of sales when these products are shipped to customers from our
     facility. In addition, certain products sold by the company are subject to
     a limited product quality warranty. The company accrues for estimated
     incurred but unidentified quality issues based upon historical activity and
     known quality issues if a loss is probable and can be reasonably estimated.
     The standard limited warranty period is one to three years. Quality
     returns, refunds, rebates and discounts are recorded net of sales at the
     time of sale and estimated based on past history. Historically, we have not
     experienced material differences between our estimated amounts of quality
     returns, refunds, rebates and discounts and the actual results. In all
     contracts, there is no price protection or similar privileges in relation
     to the sale of goods."

<PAGE>

Ms. Kristin Lochhead, Staff Accountant
Division of Corporation Finance
United States Securities and Exchange Commission
May 20, 2005
Page 3

     Bonso's management confirms that its revenue recognition policies do not
     differ among its significant product lines (i.e. sensor based versus
     wireless products) and among various marketing venues use by the Company
     (i.e. distributors and direct sales force), and do not vary in different
     parts of the world.

     The total amounts of quality returns, refunds, rebates and discounts
     granted to customers for the years ended March 31, 2002, 2003 and 2004 were
     US$620,000 , US$501,000 and US$472,000, respectively, which management
     considers insignificant to the Group for disclosure purpose.

     Bonso's management has advised that they understand that:

     o    Bonso is responsible for the adequacy and accuracy of the disclosure
          in the filings;

     o    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

     o    Bonso 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.

     If you have any questions or wish to discuss anything further, please do
not hesitate to contact the undersigned.

                                            Very truly yours

                                            Schlueter & Associates, P.C.

                                            By /s/ Henry F. Schlueter
                                            -------------------------
                                            Henry F. Schlueter

     C: Bonso Electronics International Inc.
</TEXT>
</DOCUMENT>