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ADEPT TECHNOLOGY, INC.

                                           FOIA CONFIDENTIAL TREATMENT REQUESTED

                                 April 12, 2005

(925) 245-3413

By Overnight Delivery and EDGAR

Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Mail Stop 0306
Washington, DC  20549
Attention:  Gary Todd

         Re:      Adept Technology, Inc.
                  Form 10-K for the fiscal year ended June 30, 2004
                  Form 10-Q for the quarter ended October 2, 2004
                  Form l0-Q for the quarter ended January 1, 2005
                  File No. 000-27122

Ladies and Gentlemen:

         On behalf of Adept  Technology,  Inc.  ("Adept" or "the  Company"),  we
hereby  respond  to your  comment  letter  dated  March 29,  2005 (the  "Comment
Letter") relating to the  above-referenced  filings by Adept with the Securities
and Exchange  Commission  (the  "Commission").  For ease of reference,  the bold
headings and numbered  paragraphs  below correspond to the headings and numbered
comments in the Comment Letter.

         Adept  requests,  pursuant to the provisions of Commission  Rule 83 (17
C.F.R.  ss.  200.83),  confidential  treatment of the Annex A accompanying  this
letter as noted and  bearing  the Bates  Number  ADEO CTR 001- ADEO CTR 002 that
includes   information   being  provided   supplementally   to  the  Staff  (the
"Confidential Information"),  under the Freedom of Information Act (5 U.S.C. ss.
552) (the "FOIA"). The Confidential  Information contains  confidential business
information,  which we believe is covered by one or more exemptions in the FOIA.
Such  information,  if made  public,  could  adversely  affect  Adept.  A letter
detailing Adept's confidential  treatment request accompanies this letter and is
also being  filed with the Office of Freedom  of  Information  and  Privacy  Act
Operations.

  3011 Triad Drive * Livermore, CA 94550 * (925) 245-3400 * (925) 960-0452 Fax
                                  www.adept.com

<PAGE>
Securities and Exchange Commission
Attention: Gary Todd                                              April 12, 2005
Page 2

Form 10-K for the fiscal year ended June 30, 2004
-------------------------------------------------

Item 7. Management's Discussion and Analysis of Financial Condition and
-----------------------------------------------------------------------
Results of Operations - Page 16
-------------------------------

Critical Accounting Policies and Estimates - Page 17
----------------------------------------------------

1.       Critical  accounting  policy  disclosure  should provide  insight about
         complex  judgments  and estimates  that  underlie  your key  accounting
         policies.  That information should generally expand upon and not merely
         repeat basic accounting policies. We see that the revenue discussion is
         mostly factual.  Please expand that item to more specifically  identify
         and describe the nature and extent of complex  estimates and subjective
         judgments associated with your revenue practices,  including discussion
         about the  susceptibility  of those  estimates and judgments to change.
         That  disclosure  should also  describe  the  factors  you  consider in
         evaluating the  significance  of subjective  matters in determining the
         amounts and timing of revenue.  Apply in future filings. Refer to FR-60
         and Exchange Act release 34-48960 for further guidance.

         In response to the Staff's comment, Adept intends to disclose in future
         filings any complex  judgments and estimates  underlying key accounting
         policies.   Adept   supplementally   advises   the   Staff   that   the
         discontinuation  of our  Solutions  business  late in  fiscal  2004 has
         simplified  revenue  recognition  matters  for  fiscal  2005 and future
         years.

Results of Operations
---------------------

Net Revenues - Page 21
----------------------

2.       Where  significant,  please  quantify the impact of changes in exchange
         rates on reported revenues and expenses. Apply in future filings.

         Management  concluded  that the impact of changes in exchange  rates on
         reported  revenues  and expenses  was not  significant  in fiscal 2004.
         Adept will  include  this  disclosure  in future  filings if the impact
         becomes significant.

Item 9A. Controls and Procedures - Page 47
------------------------------------------

3.       We note your  statement  that "the  design of any system of controls is
         based in part upon certain  assumptions  about the likelihood of future
         events,  and there can be no assurance  that any design will succeed in
         achieving  its stated  goals  under all  potential  future  conditions,

<PAGE>
Securities and Exchange Commission
Attention: Gary Todd                                              April 12, 2005
Page 3

         regardless of how remote." You should delete the  referenced  sentence.
         Alternatively,  you should expand 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  officers  concluded  that
         disclosure  controls and  procedures  are effective at that  reasonable
         assurance  level.  Refer to Section II.F.4 of  Management's  Reports on
         Internal  Control  Over  Financial   Reporting  and   Certification  of
         Disclosure  in Exchange  Act  Periodic  Reports,  Release No.  33-8238,
         available on our website at  www.sec.gov/rules/final/33-8283.htm  Apply
         in future filings, including quarterly filings.

         Adept will revise its disclosures in future filings in response to this
         comment. Adept intends to include in its Item 9A discussion, disclosure
         substantially similar to the following:

         Adept's disclosure  controls and procedures are designed to ensure that
         the information required to be disclosed in our reports filed under the
         Exchange Act is recorded, processed, summarized and reported within the
         time periods  specified in the SEC's rules and forms, and to reasonably
         assure that such  information is accumulated  and  communicated  to our
         management,  including the CEO and CFO, as appropriate, to allow timely
         decisions  regarding required  disclosure.  A control system, no matter
         how well  conceived  and  operated,  can provide only  reasonable,  not
         absolute,  assurance  that the objectives of the control system are met
         under all potential  conditions,  regardless of how remote, and may not
         prevent  or detect all error and all  fraud.  Because  of the  inherent
         limitations  in all control  systems,  no  evaluation  of controls  can
         provide  absolute  assurance  that all control  issues and instances of
         fraud, if any, within Adept have been detected.

Financial Statements
--------------------

Consolidated Statements of Operations - Page 57
-----------------------------------------------

4.       We see from your business and MD&A  discussions  that you have revenues
         from services  provided to your  customers and royalties from licenses.
         Tell us how your income  statement  considers the  formatting  guidance
         from Rules 5-03(b)(1) and 5-03(b)(2) to Regulation S-X.

         Adept's MD&A (page 21)  discloses  revenues as  emanating  from its two
         business  segments,  consisting of Components  revenue of $30.8 million
         and Services and Support  revenues of $18.3  million.  A more  detailed
         discussion of these revenues is included in Annex A.  Approximately 90%
         of the Parts &  Services  revenue  item  (which  comprises  most of the
         Services  and Support  revenues)  consists of revenue  from the sale of

<PAGE>
Securities and Exchange Commission
Attention: Gary Todd                                              April 12, 2005
Page 4

         spare  parts  and  refurbished  robots.  Revenue  from  service-related
         activities   (such  as   maintenance,   repair,   and   training)   was
         approximately  5%  of  total  revenue  in  fiscal  2004.  Revenue  from
         licensing  and  royalties  was less than 1% of total  revenue in fiscal
         2004. Thus neither category required separate disclosure on the face of
         the income statement in accordance with Regulation S-X Rules 5-03(b)(1)
         and  5-03(b)(2).  In future filings we intend to expand our description
         of our  Services and Support  business  segment to clarify that segment
         revenues   include  sales  of  spare  parts  and  refurbished   robots.
         Furthermore, to the extent our service revenues meet the thresholds for
         separate disclosure in our income statement, we will do so.

Note I: Summary of Significant Accounting Policies
--------------------------------------------------

Revenue Recognition - Page 63
-----------------------------

5.       We see the general  criteria you apply for product revenue  recognition
         purposes.  Tell us more about the terms and conditions of  transactions
         with systems integrators.  Show us how you apply the disclosed criteria
         for  transactions  with those entities and  demonstrate to us that your
         revenue  practices are appropriate for transactions with those parties.
         We are particularly  interested in considerations that drive the timing
         of revenue. Your supplemental response should be detailed and specific.

         To facilitate the Staff's  understanding of Adept's revenues practices,
         we have provided a detailed  breakdown of fiscal 2004 revenues in Annex
         A. Adept  products are  primarily  sold by its internal  sales force to
         system   integrators,   OEM's,  and  end  users.  We  generally  supply
         off-the-shelf  components to our direct customers (systems integrators,
         OEM's,  and end users) who use our  components in specific  application
         solutions.   The  specific  solutions  generally  use  custom  designed
         fixtures (which we do not supply) with our robots and controllers.  The
         overall  solution is controlled  by customer  tailored  software  (such
         tailoring may make use of our software  templates  and vision  enabling
         tools).  It is our customers who assemble  these  elements into complex
         systems,  and it is these  systems which may have  acceptance  criteria
         attached to them. The  approximately  250 system  integrator  customers
         accounted for about 60% of Adept component sales in fiscal 2004.  Sales
         to system  integrators  are  recognized at point of shipment from Adept
         facilities  because title and risk of loss passes to the buyers at this
         point and  system  integrators  have no right of return  other than for
         defects covered by warranty. No acceptance criteria or multiple element
         arrangements exist with respect to Adept's sales to system integrators.

<PAGE>
Securities and Exchange Commission
Attention: Gary Todd                                              April 12, 2005
Page 5

6.       We see the  complexity of the products you provide.  Tell us about post
         shipment  obligations  (training,  installation,  etc.) and  acceptance
         protocols associated with product sales. Tell us how you consider these
         matters in determining the timing of revenue. Unless insignificant, you
         should present disclosure about these matters in future filings.

         Adept  supplementally  informs the Staff that standard  Adept  products
         with standard specifications are sold to system integrators, OEM's, and
         end users.  Training,  installation  and  application  programming  are
         provided at the  customer's  option under separate  arrangements.  Post
         shipment obligations are not included in product sale prices. There are
         no acceptance  criteria  related to robots,  controllers,  spare parts,
         maintenance,  repair, and training,  and our customers have no right of
         return other than for product defects  covered by warranty.  We have no
         history of significant product returns.  Since we have no post shipment
         obligations for product sales no disclosure is necessary.

7.       As a  related  matter,  you  indicate  that you  generally  do not have
         multiple element  arrangements.  In light of the apparent complexity of
         your products tell us more about the terms of product sales and explain
         the bases for that assertion.  The supplemental response should explain
         how you have  considered  the  requirements  of EITF  00-21.  Please be
         detailed and specific.

         As can be seen in Annex A, over 95% of Adept's sales consist  primarily
         of direct  shipments of Adept produced robots,  controllers,  component
         parts,  and  software  to  system  integrators,  OEM's,  and  end  user
         customers.  There are no significant  multiple element  arrangements as
         described in EITF 00-21 and SOP 97-2, as amended.

8.       Tell us  about  return  policies  and  practices,  including  how  your
         policies  are  considered  in  determining  the timing of  revenue.  As
         relevant,  tell us how your revenue practices consider the requirements
         of FAS 48.

         Adept supplementally advises the staff that our product's Terms of Sale
         do not include rights of return;  therefore,  we do not maintain return
         reserves.  We do not  have any  historical  experience  of  significant
         returns  of  product  or  software.   Our   warranty   policy  is  also
         encapsulated in our Terms of Sale and states that we will give a refund
         at our  discretion,  and only if there  is an  identified  fault in the
         product,  and only if the customer has complied  with Adept's  approved
         maintenance  schedules  and  procedures,  and the  product has not been
         subject to abuse.
<PAGE>
Securities and Exchange Commission
Attention: Gary Todd                                              April 12, 2005
Page 6

         Adept also  supplementally  informs the Staff that Adept  Services  and
         Support  spare parts  shipments can be returned by customers for credit
         within  10 days.  Returns  occur on less than  one-half  of 1% of parts
         sales,  and usually for emergency  shipments  where our customers order
         extra parts to ensure their  technical  problems are fixed. We have not
         reserved  for these sales  returns  because  the amounts  have not been
         material.

9.       For software revenue purposes,  tell us more about how you evaluate the
         criteria from SOP 97-2, as amended.  For instance,  describe the nature
         and extent of post  contract  support  generally  associated  with your
         license   arrangements  and  describe  the  criteria  you  evaluate  in
         assessing  whether that post shipment support is significant.  Describe
         your practices when that support is deemed significant. How are upgrade
         or  enhancement  rights  considered  in your  practices?  Do you  apply
         multiple-element accounting for software transactions? If not, why not;
         and,  if  so,  how  do  you  apply  the  multiple-element  method?  The
         supplemental