SecProbe.io

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Mail Stop 4-06

April 1, 2005

Thomas McNeill
Vice President, Chief Financial Officer
   and Secretary
Global Payment Technologies, Inc.
425B Oser Avenue
Hauppauge, New York 11788

RE:		Global Payment Technologies, Inc. (file no. 033-86352)
		Form 10-K: For the Year Ended September 30, 2004
		Form 10-Q: For the Quarterly Period Ended December 31,
2004

Dear Mr. McNeill,

We have reviewed the above referenced filings and have the
following
comments. Please note that we have limited our review to the
matters
addressed in the comments below.  Where indicated, we think you
should revise your documents 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 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 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 on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 8-K filed February 2, 2005

1. We note that you present EBITDA because it is a "widely
accepted
financial indicator and is used by investors and analysts to
measure
performance." Supplementally, explain to us how you considered the
following related to your presentation of this non-GAAP
information:
* Question 15 of the Frequently Asked Questions Regarding the Use
of
Non-GAAP Financial Measures (FAQ) indicates that EBITDA should be
reconciled to net income or loss as presented in the statement of
operations in accordance with GAAP; and
* Question 15 also indicates that EBITDA excludes recurring
charges
and you should consider Question 8 of the FAQ if you present it as
a
performance measure. Question 8 explains that the following
disclosures may be necessary to ensure that the presentation is
not
misleading:
* The manner in which management uses EBITDA to conduct or
evaluate
its business;
* The economic substance behind management`s decision to use such
a
measure;
* The material limitations associated with use of EBITDA as
compared
to the use of the most directly comparable GAAP financial measure;
* The manner in which management compensates for these limitations
when using EBITDA; and
* The substantive reasons why management believes EBITDA provides
useful information to investors.

Form 10-K for the Fiscal Year Ended September 30, 2004
Note 2. Summary of Significant Accounting and Reporting Policies
(b) Revenue Recognition, page F-8

2. We note that you restated your financial statements in fiscal
2002
to report capitalized software costs in accordance with SFAS 86.
Supplementally, explain the impact, if any, of this restatement on
your determination of whether SOP 97-2 applies to your revenue
arrangements. Update your conclusion for developments in your
business, marketing and products that have occurred since your
restatement. Refer to paragraph 2 and footnote 2 of the SOP in
your
response.

Global Payment Technology Pty Limited Financial Statements
Statements of Income, page F-27

3. We note that Global Payment Technology Pty Limited does not
separately report costs of revenue related to purchases from
Global
Payment Technologies, Inc. within their statements of income.
Supplementally, explain to us how you considered Rule 4-08(k) of
Regulation S-X that requires that such amounts be separately
reported.

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.  Detailed cover
letters greatly facilitate our review.  Please 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 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 Brent Watson, Staff Accountant, at (202) 824-5494,
Mark Kronforst, Senior Staff Accountant, at (202) 824-5341 or me
at
(202) 942-1800 if you have any questions regarding these comments.

							Very truly yours,

							Craig Wilson
							Senior Assistant Chief
Accountant
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Global Payment Technologies, Inc.
April 1, 2005
Page 1 of 4

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