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Correspondence Letter - July 12, 2005

LETTERHEAD OF SBS TECHNOLOGIES, INC.

7401 Snaproll NE

Albuquerque, NM  87109

(505) 875-0600

July 12, 2005

VIA EDGAR AND OVERNIGHT COURIER

Mr. Craig D. Wilson

Senior Assistant Chief Accountant

Securities and Exchange Commission

Division of Corporate Finance
Mail Stop 4-6

450 Fifth Street, N.W.

Washington, DC 20549-0406

RE:	SBS Technologies, Inc.

Form 10-K for the fiscal year ended June 30, 2004; and Form 10-Q for the fiscal
quarter ended March 31, 2005

File No. 001-10981

Dear Mr. Wilson:

We have reviewed your comment letter dated June 29, 2005, sent to SBS
Technologies, Inc. ("SBS" or the "Company") with respect to
your review of SBS' Form 10-K for the fiscal year ended June 30, 2004 filed on
September 13, 2004, and SBS' Form 10-Q for the fiscal quarter ended March 31,
2005 filed on May 10, 2005.

Our response to each comment set forth in your comment letter is included
below.  For your convenience, the Staff's comments have been stated below in
their entirety, in bold, with the responses to a particular comment set out
immediately under the comment.

Staff Comment:  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.

Company Response:  SBS designs and builds embedded computer
products.  Based on our review and analysis of SFAS No. 86, we did not consider
the guidance applicable to our business.  We reached this conclusion principally
because we sell embedded computer components and are not in the business of
selling software.  As a result, we have not followed the guidance in SFAS No.
86.

Based on your comment, we reconsidered all of our intangible assets,
including acquired technology, and believe that the only assets which could
potentially fall under the guidance of SFAS No. 86 are our license agreements.
The license agreements capitalized on our books relate to amounts paid to third
parties to incorporate their firmware or drivers into our embedded computer
products.  At the date acquired, we recorded the amounts paid for these license
agreements as intangible assets with a finite life in accordance with the
guidance of APB Opinion No. 17 (superseded by SFAS No. 142), which we believed
was appropriate.  Once capitalized, we classified these license agreements as
intangible assets together with all other intangible assets, consistent with
Concepts Statement No. 5, because we believed grouping items with essentially
similar characteristics was appropriate.  As a result of these assets having
similar characteristics, we recorded and presented amortization expense in the
income statement together with all other intangible asset amortization expense.
We also provided prominent disclosure of the accounting for intangible assets in
the notes to the consolidated financial statements.  In conclusion, we believed
that the combined presentation of our intangible assets and the presentation of
all of our intangible asset amortization expense as a separate line in our
income statement within operating expenses was appropriate to provide full
disclosure to the readers of our consolidated financial statements and that this
disclosure was not misleading.

Upon review of paragraph 17 of the implementation guide to SFAS No. 86, we
believe that the presentation of the amortization expense for our license
agreement intangible assets may have been more appropriately reported as a
component of costs of sales.  Based on review of the activity reported in our
June 30, 2004 Form 10-K, we noted that the amortization expense for such license
agreements during the years ended June 30, 2004, 2003 and 2002 was approximately
$494,000, $597,000 and $424,000, respectively, which represents 0.37%, 0.52% and
0.35% of sales and gross profit, respectively.  As a result, we do not believe
that an amendment to our previously filed documents is necessary as this
reclassification would have no impact on sales, operating income, net income or
earning per common share.  However, we will change the classification of
amortization expense for our license agreements as cost of sales on a
prospective basis in our Form 10-K for the fiscal year ended June 30, 2005 for
all years presented.

Staff Comment:  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 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.

Company Response:  We account for our inventories using a standard
cost system, and we believe the carrying value approximates the lower of
weighted average cost or market.  Our current accounting procedures incorporate
the routine monitoring of purchase price variances, often performed daily, and
we investigate all significant price variances as they occur.  The determination
of an appropriate standard cost is dependent on the number of units purchased
(standard order quantity) and several other factors.  However, upon review of
the purchase price variances, any significant standard cost adjustments are
recorded throughout the period as adjustments to the inventory carrying amount.
In addition, at the end of every quarter, we update the standard costs for all
component parts in inventory to ensure that our standard costs reflect current
conditions (i.e. weighted average cost).  Thus, we believe the frequency at
which we review our standard costs to ensure they approximate weighted average
cost is sufficient and consistent with the guidance and requirements of footnote
3 of ARB 43.

In addition, we evaluate the carrying value of our inventory on a quarterly
basis at or near the balance sheet date to determine whether we have any excess
or obsolete inventory on hand.  A number of factors are evaluated by inventory
and product personnel, including those discussed in our critical accounting
policy disclosures in our Form 10-K, to ascertain whether or not a write-down in
value for a given product is required.  We perform this review to ensure that
the carrying value of our inventory is not in excess of current market
conditions to ensure compliance with our policy of the lower of weighted average
cost or market.  As noted in your comment, in fiscal 2002, we recorded inventory
write-downs for the reasons discussed in our Form 10-K.  Once the carrying value
of inventory is written down, our policy is that the cost for such items is not
written back up in accordance with SAB 100.

Staff Comment:  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.

Company Response:  We apply the revenue recognition guidance in
SAB 104 to the sale of our embedded computer products.  Revenues are recorded
upon the fulfillment of a customer purchase order, and revenue recognition is
dependent upon the shipping terms which dictate when title passes from SBS to
the customer.  The majority of our products are shipped to customers under the
terms FOB origin; however, we do ship products to certain customers under FOB
destination terms.  For all FOB destination shipments, revenue recognition is
deferred until the goods arrive at the customer's location, which we verify by
review of the orders with the carrier (UPS, FedEx, etc.).  Occasionally, the
terms of customer purchase orders contain customer acceptance provisions which
may preclude SBS from recognition of revenue upon shipment.  SBS' policy for
recognition of revenue when customer acceptance provisions exist is to defer
revenue recognition until acceptance by the customer unless we demonstrate the
product shipped met the customer specified criteria upon shipment, provided all
other revenue recognition criteria were met.  In these situations, we evaluate
the terms of the transactions prior to reaching the conclusion regarding revenue
recognition.  Our evaluations consider several factors, including but not
limited to, historical experience with the same specifications and functionality
of the particular product being shipped, whether conditions under which the
customer intends to operate the equipment can be effectively replicated, as well
as discussions with project managers or engineers to determine whether the
product shipped meets the customer's specifications.  We believe our policy in
these instances is consistent with the guidance in SAB Topic 13A3 - question
1(d).

In connection with the sale of SBS' embedded computer products, we often
provide software drivers, board support packages and other specialized tools
which enable the use of our products in specific applications.  However, we are
not in the business of selling software and we do not sell software separate
from our board level products or systems.  Our marketing efforts are focused
specifically on embedded computer products.  Any software contained within our
embedded computer products does not function separately and is not sold or
marketed separately.  All firmware and/or software drivers provided with our
products are designed to work specifically with SBS products only and will not
work with embedded computer products provided by another vendor.  Thus, we
believe that software contained within our embedded computer products (embedded
computer boards or fully integrated systems) is incidental to the product as a
whole and meets the definition of "incidental to the product as a
whole" provided in paragraph 2 of SOP 97-2.

Staff Comment:  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.

Company Response:  As noted in our response to comment number 3,
revenues are recorded upon the fulfillment of a customer purchase order, and
revenue recognition is dependent upon the shipping terms which dictate when
title passes from SBS to the customer.  The majority of our products are shipped
to customers under the terms FOB origin in which title passes to the buyer upon
shipment; however, we do ship products to certain customers under FOB
destination terms.  For all FOB destination shipments in which title passes to
the buyer upon receipt at the buyer's location, revenue recognition is deferred
until the goods arrive at the customer's location.  We did not believe that
disclosure of our customary shipping terms (i.e. FOB shipping point) within our
accounting policy note was necessary or meaningful to a reader because we do
have some FOB destination transactions, even though they are much less frequent
than FOB origin transactions.  However, we will provide additional disclosure of
our customary shipping terms going forward, but we do not believe that the
addition of this information represents a material change to our previously
filed documents.

Staff Comment:  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.

Company Response:  Our terms and conditions of sale to customers
other than foreign distributors, consisting of our standard terms and conditions
and separately negotiated terms and conditions with OEM customers, do not
include any contingencies for return rights, price protection, or stock rotation
rights.  Our customers only have the right to return defective products for
repair or replacement under our standard product warranties, which we account
for in accordance with SFAS No. 5.

Our agreements with 33 of our 35 foreign distributors are consistent with our
standard terms and conditions and do not include any contingencies for return
rights, price protection, or stock rotation rights.  However, 2 out of 35 of our
foreign distributors operate under legacy agreements which contain stock
rotation rights limited to 5% of trailing twelve-month purchases from SBS
but no other arrangements for either return rights or price
protection.  One of these customers does not stock SBS inventory, and sales to
the other customer have been less than 0.50% of total consolidated sales for
each period presented in the Form 10-K.  In addition, we have never had any
product returns from either of these customers.  Based on our historical
activity and our knowledge of these customers, we believed the likelihood of any
significant product returns was remote.  As a result, we did not record any
contingent liabilities related to these limited stock rotation rights.

Staff Comment:  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 distributors any incentives such as discounts or stock rotation rights
and if so, tell us how you account for such consideration.

Company Response:  Consistent with our response to comment number
3 above, we apply the revenue recognition guidance in SAB 104 to the sale of our
embedded computer products to our customers, including foreign distributors.
Revenues are recorded upon the fulfillment of a customer purchase order, and
revenue recognition is dependent upon the shipping terms which dictate when
title passes from SBS to the customer.  The foreign distributors we utilize to
sell our products in certain foreign jurisdictions are SBS' customers for such
product sales.  Thus, we bill and collect receivables from our foreign
distributors and the terms we provide to them are consistent with terms provided
to original equipment manufacturers.

As noted in our response to comment number 5 above, our agreements with 33 of
our 35 foreign distributors are consistent with our standard terms and
conditions and do not include any contingencies for return rights, price
protection, or stock rotation rights.  However, 2 out of 35 of our foreign
distributors operate under legacy agreements which contain stock rotation rights
limited to 5% of trailing twelve-month purchases from SBS but no other arrangements for either return rights or price protection.
One of these customers does not stock SBS inventory, and sales to the other
customer have been less than 0.50% of total consolidated sales for each period
presented in the Form 10-K.  In addition, we have never had any product returns
from either of these customers.  Based on our historical activity and our
knowledge of these customers, we believed the likelihood of any significant
product returns was remote.  As a result, in accordance with SFAS No. 5, we did
not record any contingent liabilities related to these limited stock rotation
rights.

Our agreements with foreign distributors contain provisions for sales
discounts from list prices in connection with their purchase of our products.
We account for all discounts from list prices as a reduc