SecProbe.io

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								June 29, 2005

Fax (505) 875-0404
Mail Stop 0406

Clarence W. Peckham
Chief Executive Officer
SBS Technologies, Inc.
2400 Louisiana Blvd. NE
AFC Bldg 5
Suite 600
Albuquerque, NM 87110

      RE: 	SBS Technologies, Inc
 		Form 10-K Fiscal Year Ended June 30, 2004
		Form 10-QSB for the Fiscal Quarter Ended March 31, 2005
 		File No. 001-10981

Dear Mr. Peckham:

      We have reviewed the above referenced filing and have the
following comments.  Please note that we have limited our review
to
the matters addressed in the comments below.  We may ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please be as detailed as necessary in your
explanation.  After reviewing this information, we may 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 comments 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 June 30, 2004

Item 8. Financial Statements and Supplementary Data

Consolidated Statements of Operations

1. We note that you classified amortization of intangible assets,
including acquired technology, within operating expenses.  Tell us
how you considered Question 17 of the SFAS No. 86 Implementation
Guide in determining that classification of the amortization for
acquired technology and any related impairment charges as cost of
sales was not necessary.

Notes to the Consolidated Financial Statements

Note 1 - Summary of Significant Accounting Policies

(c) Inventories

2. Your disclosure indicates that your inventories are valued at
standard cost which approximates the lower of weighted average
cost
or market.  We also note from disclosure under Note 4 that you
recorded write-downs of approximately $15 million in inventory in
2002.  Please explain how you determined that standard cost
approximates lower of weighted average cost or market and tell us
your process for valuing your inventory.  Also, tell us how often
the
Company conducts an inventory valuation and tell us how you
considered footnote 3 of ARB 43 in determining that such
valuations
are at reasonable intervals.

(g) Revenue Recognition

3. Please tell us whether you are using SOP 97-2 or SAB 104 in
recognizing revenue on your product sales and explain your revenue
recognition policy for each major type of arrangement. Also, tell
us
how you considered paragraph 2 of SOP 97-2 in determining that
software included in your products sales is incidental to the
product
as a whole.

4. We note your disclosure that revenue from product sales is
recognized upon shipment to customers and upon the transfer of
title
to customers.  Describe your typical shipping terms and indicate
when
title passes to customers.

5. Tell us whether your arrangements include contingencies such as
return rights, price protection, stock rotation rights, etc., and
tell us how you account for such contingencies.  Describe
significant
assumptions, material changes and reasonably likely uncertainties.

6. We note from your disclosures in the Business discussion for
Sales
and Marketing,  that in certain foreign countries, you sell
products
through distributors.  Please tell us how you recognize revenues
under arrangements with distributors.  Tell us how these
arrangements
differ from arrangements with original equipment manufacturers, if
at
all.  Also, tell us if you offer your distributors any incentives
such as discounts or stock rotation rights and if so, tell us how
you
account for such consideration.

Item 9A. Controls and Procedures
7. We note your statement that the chief executive officer and
chief
financial officer have concluded that the Company`s disclosure
controls and procedures were effective "subject to the limitations
noted above."  We further note your statement that "a control
system,
no matter how well designed and operated, can provide only
reasonable, not absolute, assurance that the control system`s
objectives will be met." Please tell us if the Company`s
disclosure
controls and procedures were designed to provide a reasonable
assurance level of achieving their objectives.  Also, tell us what
consideration you have made to include this information in your
Item
9.A disclosures pursuant to to Section II F. 4 of Management`s
Reports on Internal Control over Financial Reporting and
Certification of Disclosure in Exchange Act Reports, SEC Release
No.
33-8238, available on our website at
http://www.sec.gov/rules/final/33-8238.htm.

* * * * *

       As appropriate, please amend your filing and respond to
these
comments 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 responses to our comments 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 responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact David Edgar at (202)-551-3459 or Kathleen
Collins at (202) 551-3499, or the undersigned at (202) 551-3730 if
you have any questions regarding comments on the financial
statements
and related matters.

							Very truly yours,

							Craig D. Wilson
							Senior Assistant Chief
Accountant

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Clarence W. Peckham
SBS Technologies, Inc
June 29, 2005
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