SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010

February 1, 2008

via U.S. mail and facsimile

Mr. William R. Retterath     Chief Financial Officer
Daktronics, Inc.
331 32
nd Avenue
Brookings, SD  57006

RE: Daktronics, Inc.
Form 10-K for the Fiscal Year Ended April 28, 2007
  Filed June 22, 2007
    File No. 000-23246

Dear Mr. Retterath:    We have reviewed your filing and have  the following comments.  If you disagree
with a comment, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with supplemental information so we may better understand your  disclosure.  After reviewing this
information, we may or may not raise additional comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or on 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 April 28, 2007

Intellectual Property

1. In future filings, please include informati on about material patents, including their
duration, pursuant to Item 101( c)(1)(iv) of Regulation S-K.

Mr. William R. Retterath
Daktronics, Inc.
February 1, 2008 Page 2  Customers

2. In future filings, please identify the cu stomer from which you derived over 10%
of your revenue pursuant to Item 101(c)(1)(vii) of Regulation S-K.
 Competition

 3. At the beginning of the third paragra ph, you state that the competitive landscape
has changed significantly due to consolidation of your competitors.  In future filings, please identify your main competitors.
 Risk Factors

We enter into fixed-priced contracts on a regular basis

4. You state that you have certain long term  contracts and we note your discussion
about long-term contracts in Note 7 of the Notes to Consolidated Financial Statements.  In future filings please include a summary of the material terms of such contracts in your business section and file them as exhibits if required under
Item 601(b)(10) of Regulation S-K.

Statements of Income

5. In future filings, please separately disc lose product sales and service revenues
pursuant to Article 5-03.1 of Regulation S- X. If service revenues are immaterial
then please provide clarifying disclosure in future filings.

Results of Operations

6. Please expand your discussion of results of operations in future filings to quantify the reasons for the fluctuati ons in your line items year  over year.  Your current
disclosures are unclear to readers as to which are the significant factors.  For example, we note the following:

• You disclose the most significant factors a ffecting gross profit margin in fiscal
year 2007 as compared to fiscal year 2006 included the costs of bringing additional capacity on-line which include d new facilities, higher costs of
depreciation and inefficiencies in the manufacturing process, the costs associated with implementing lean manufacturing techniques, performance on
contracts, the impact of operating at capacity during a sign ificant portion of
the year and higher overall warranty costs.

Mr. William R. Retterath
Daktronics, Inc.
February 1, 2008 Page 3
• You disclose selling expenses increase d in fiscal year 2007 as compared to
fiscal year 2006 due to higher levels  of personnel cost s, international
expansion, employee benefits, trav el and entertainment expenses,
depreciation, telephone costs, the in creased number of sales and service
offices and other costs associated wi th a higher number of employees.
 The enhanced disclosure should enable a reader to better unders tand the extent to
which operating results were impacted by specific factors. See Section 501.12.b.4
of the Financial Reporting Codification.

Liquidity and Capital Resources

7. Please revise your liquidity and capital reso urces disclosures in future filings to
discuss the underlying reasons for the changes in the account balances that
affected your cash flows year over year.  For example, please discuss the reasons
for the increase in your accounts receivable s, inventories, and costs and estimated
earnings in excess of billings.  Consider  providing a discussion of days sales
outstanding ratio and invent ory turnover ratio to a llow your readers to better
understand the increases in these balan ces. See Section 501.13.b of the Financial
Reporting Codification.

Note 16. Quarterly Financial Data (Unaudited)

8. In future filings, please provide clarifyi ng disclosure either here or in MD&A
about the reasons for 4th quarter earnings fluctuations. We note that 4th quarter
earnings declined 50% whereas sales incr eased 22%. See the analogous guidance
in paragraph 31 of APB 28.

Executive Compensation

Compensation Discussion and Analysis
  Setting Executive Compensation

 9. We note that (i) you do not provide any information, including quantification, on the specific items of corporate performance taken into account in making base salary decisions (Items 4 02(b)(1)(v) of Regulation S- K); (ii) you do not identify
how the maximum amount of an annual incentive bonus is determined; (iii) you
state that the Board of Directors and the Compensation Committee have
discretion in increasing or decreasi ng payouts to a named executive officer;
however, you do not identify any particular exercises of discretion regarding
compensation decisions (Item 402(b)(vi) of  Regulation S-K); and (iv) you do not
list any factors considered in decidi ng to increase or decrease compensation

Mr. William R. Retterath
Daktronics, Inc.
February 1, 2008 Page 4
materially.   In future filings, please addr ess all of the requirements of Item 402(b)
of Regulation S-K.
 10. In accordance with Item 402(b)(1)(xi) of Re gulation S-K, in future filings please
add a discussion related to payments in c onnection with a change in control event
and how those payments are trigge red.  We note your discussion under
subheading “Post-Employment Compensation. ”  In future filings, please expand
your discussion in this section to itemi ze each payment made in connection with,
but not limited to, (i) termination of  a named executive officer’s employment
following a change in control event, (ii)  termination without cause or for good
reason; (iii) termination other than without cause or for good reason.  Also,
further disclose whether the vesting of op tion awards is accele rated as a result of
such events.

11. In your discussion of “Deferred Compensation Arrangements” in future filings please include a short summary of the mate rial terms with respect to payouts,
withdrawals and other distributions.  See
 Item 402(c)(3)(iii) of Regulation S-K.
 Signatures

12. Please note in future filings that the Form 10-K must be signed by the principal
accounting officer or contro ller of the company.

Form 10-Q for the Quarterly Period ended October 27, 2007

Results of Operations, page 19

13. We note beginning in your Form 10-Q for the quarterly period ended October 27,
2007, you have begun to present your busines s within five reportable segments,
and as a result, you now provide a separate discussion of net sales for each of your segments.  In future filings, plea se expand your discussion of results of
operations to also include a discussion of  profitability and cash needs by segment.
For example, the disclosure should clear ly explain why operating income in the
Live Events segment declined 60% in the quarter whereas the segment’s sales declined 22%.  Refer to Section 501.06.a of the Financial Reporting Codification.

*    *    *    *

Mr. William R. Retterath
Daktronics, Inc.               February 1, 2008 Page 5    Please respond to these comments with in 10 business days, or tell us when you
will provide us with a response.  Please pr ovide us with a supplemental response letter
that keys your responses to our comment s and provides any requested supplemental
information.  Detailed letters greatly f acilitate our review.  Please submit your
supplemental response on EDGAR as a corres pondence file.  Pleas e understand that we
may have additional comments after reviewing your responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision.  Since the company and its
management are in possession of all facts re lating 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
   In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact Era Anagnosti, Staff A ttorney, at (202) 551-3369 or, in her
absence, to Jennifer Hardy, Legal Branch Chief, at (202) 551-3767, if you have any
questions regarding legal or disclosure matters.  Please contact Ryan Rohn, Staff
Accountant, at (202) 551-3739 or, in his absence, to Al Pavot , Staff Accountant, at (202)
551-3738, or to the undersigned at (202) 551-3355 if you have questions regarding comments on the financial statements and related matters.         S i n c e r e l y ,            T e r e n c e  O ’ B r i e n         Accounting Branch Chief