SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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Mail Stop 6010
July 8, 2005

Via U.S. Mail and Facsimile

Mr. Frederick J. Hirt
Chief Financial Officer and Senior Vice President - Finance
Arrow International, Inc.
2400 Bernville Road
Reading, PA 19605

      Re:	Arrow International, Inc.
		Form 10-K for the year ended August 31, 2004
Filed November 12, 2004
Forms 8-K dated March 21, 2005 and June 20, 2005
      File No. 000-20212

Dear Mr. Hirt:

      We have reviewed your filing and have the following
additional
comments.  We have limited our review to only your financial
statements and related disclosures and do not intend to expand our
review to other portions of your documents.  Where indicated, we
think you should revise your document in future filings in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  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.

Forms 8-K Dated March 21, 2005 and June 20, 2005

1. We note your response to prior comments four and six.  Please
tell
us more details about why you believe the presentation of the non-
GAAP measures was not confusing to investors.

2. We reference your response to prior comment 4 in our letter
dated
April 25, 2005 and your disclosure in the Form 8-K dated June 20,
2005.  The disclosures in the Form 8-K dated June 20, 2005 include
a
discussion of the reasons for each of the adjustments and do not
include all of the disclosures required by paragraph (e)(1)(i) of
Item 10 of Regulation S-K and Question 8 of the FAQ Regarding the
Use
of Non-GAAP Financial Measures dated June 13, 2003 for each non-
GAAP
measure.  In future filings, revise to include a discussion, in
sufficient detail, of the following for each non-GAAP measure:
* The substantive reasons why management believes each non-GAAP
measure provides useful information to investors;
* The specific manner in which management uses each non-GAAP
measure
to conduct or evaluate its business;
* The economic substance behind management`s decision to use each
measure; and
* The material limitations associated with the use of each non-
GAAP
measure as compared to the use of the most directly comparable
GAAP
measure and the manner in which management compensates for these
limitations when using the non-GAAP measure.
3. We note your disclosure on page 9 of the Form 8-K that
management
uses the non-GAAP information to evaluate operating performance
and
as a basis for strategic planning. In future filings please
address
the following:
* Please confirm that the adjustments reflected in your non-GAAP
measures are also reflected in, and are consistent with, the
measurement principles you use to assess segment performance
pursuant
to SFAS 131.
* Otherwise, discuss the reasons for any differences in the two
approaches.   We may have further comment.

       As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  When sending supplemental
information regarding this filing, please include the following
ZIP+4
code in our address: 20549-6010.  Please understand that we may
have
additional comments after reviewing your responses to our
comments.

	You may contact Lynn Dicker at (202) 551-3616 or me at (202)
551-3605 if you have questions regarding comments on the financial
statements and related matters.  In this regard, do not hesitate
to
contact Martin James, Senior Assistant Chief Accountant, at (202)
551-3671.

Sincerely,

Brian Cascio
Accounting Branch Chief

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Mr. Frederick J. Hirt
Arrow International, Inc.
July 8, 2005
Page 2

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