SecProbe.io

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										March 21, 2005

Via US Mail and Facsimile

Mr. Geoff Bicknell
Chief Financial Officer
Nile House, Nile Street
Brighton, East Sussex
BNI 1HW, England

Re:	FutureMedia PLC
	Form 20-F for the fiscal year ended April 30, 2004
	Commission file #: 000-21978

Dear Mr. Bicknell:

We have reviewed your December 17, 2004 response letter and have
the
following comments.  Where expanded or revised disclosure is
requested, you may comply with these comments in future filings.
If
you disagree, we will consider your explanation as to why our
comments are inapplicable or a revision is unnecessary.  We also
ask
you to provide us with supplemental information so we may better
understand your disclosure.  Please be as detailed as necessary in
your explanation.  We look forward to working with you in these
respects and welcome any questions you may have about any aspects
of
our review.

* * * * * * * * * * * * * * * * * * * * * * *

Annual Report on Form 20-F for the fiscal year ended April 30,
2004

Item 7:  Major Shareholders and Related Party Transactions, page
39

1. We note your response to comment 2 that you have no further
information on the ultimate beneficial owner of Rennes Foundation
and
Jobelin Foundation.  However, we are interested in those entities
and
persons that have voting or investment power in the two
Foundations,
rather than specifically the beneficial owners.  Please
supplementally tell us, and disclose in future filings, the names
of
the entities that have voting or investment power in the Rennes
and
Jobelin Foundations and the Futuremedia officers and directors
that
have voting or investment power in those entities.

Financial Statements

Notes to the financial statements

-Revenue Recognition, page F-8

2. We note your response to comment 4.  You state that you apply
the
guidance in EITF 00-21 in recognizing revenue from Learning for
ALLTM.  EITF 00-21 addresses how to determine whether an
arrangement
involving multiple deliverables contains more than one unit of
accounting when higher literature provides no guidance.  From your
disclosure, this e-learning management system consists of
providing
all hardware, operating system software and other software
packages
and support services such as delivery, installation, training and
support.  Tell us supplementally and disclose in future filings if
you apply the guidance in SOP 97-2 in recognizing revenue from
Learning for ALLTM. If you apply the guidance in SOP 97-2, tell us
how you determined the fair value of each element.  If you believe
the software is incidental to your product and therefore you are
not
within the scope of SOP 97-2, explain to us the basis for your
conclusion.  Also, tell us how you considered the guidance
provided
in EITF 03-05.  We may have further comment based on your
response.

3. Tell us supplementally how you considered the guidance provided
in
EITF 00-3 and its impact on your revenue recognition policy.

Form 6-K dated December 15, 2004

4. We note during the six months ended October 31, 2004 you
recorded
a loss in value which was other than a temporary decline of your
investment in Luvit AB of GBP 282,000.  Tell us supplementally the
following in regards to your investment:

* what factors you considered in determining the fair value of
your
investment,
* how you determined the fair value of your investment at October
31,
2004 and
* why you believe the remaining value of your investment is
recoverable.
      Refer to paragraph 19 (h) of APB 18.

5. It appears that you have discontinued applying the equity
method
in accounting for your investment in Luvit AB in 2005 (i.e.,
recording your share of losses in Luvit AB).  Tell us why you
believe
it is not appropriate to continue recording your share of the
losses
of Luvit AB.  Also, tell us supplementally if you are required to
provide additional funding to Luvit AB beyond your investment.
Refer
to the guidance in paragraph 19(i) of APB 18.

* * * * * * * * * * * * * * * * * * * * * * *

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 supplemental information.

You may contact Claire Lamoureux at 202-824-5663 or Michele Gohlke
at
202-942-7903 if you have questions.
								Sincerely,

								Linda Cvrkel
								Branch Chief
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FutureMedia PLC
March 21, 2005
Page 1

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