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                           GLOBAL PAYMENT TECHNOLOGIES
                           ---------------------------
                              SEC LETTER RESPONSES
                              --------------------

April 14, 2005

Mr. Craig Wilson
Senior Assistant Chief Accountant
US Securities and Exchange Commission
450 Fifth street, N.W.
Mail Stop 4-6
Washington, DC 20549

Dear Mr. Wilson:

We have received your letter dated April 1, 2005, and provide the following
responses thereto, numbered as to the questions in that letter:

FORM 8-K filed February 2, 2005
-------------------------------

1.   Comment: 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:

o    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

     Response: We presented a reconciliation of net income (loss) before
provision for income taxes to EBITDA. Given that income taxes are separately
reported on the face of the income statement, and are not significant for the
periods presented, we believe it to be a clear presentation in accordance with
Regulation G as net income (loss) before taxes is an easily understandable
measure in accordance with GAAP. However, we will comply with the literal
requirement of question 15 in future filings by reconciling EBITDA to net income
(loss).

o    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:

o    The manner in which management uses EBITDA to conduct or evaluates its
     business;

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o    The economic substance behind management's decision to use such a measure;

o    The material limitations associated with use of EBITDA as compared to the
     use of the most directly comparable GAAP financial measure;

o    The manner in which management compensates for these limitations when using
     EBITDA; and

o    The substantive reasons why management believes EBITDA provides useful
     information to investors.

         Response:

     Our financial statements include costs that we expect to be non-recurring
or become immaterial in the near-term. These items include:

          o    The amortization of debt discount, which arose from issuing a
               convertible term note with warrants, will be completely amortized
               during the quarter ended March 31, 2005 as a result of the
               complete repayment (substantially through conversions to equity)
               of such debt as disclosed in our Form 8-K filed on Monday April
               4, 2005.

          o    Further, through our year ended September 30, 2002 we had
               accumulated capitalized software costs and molds and tooling in
               the amount of approximately $4.5 million for a new product
               generation, the Argus and Aurora product lines. We do not
               anticipate incurring costs of such magnitude in the future, and
               based upon current and estimated sales levels expect such costs
               to be fully amortized no later than the period ending September
               30, 2007 and 2009, with respect to the Argus and Aurora product
               lines, respectively.

          o    In addition, interest expense, which was only $34,000 per quarter
               for the last three quarters, is expected to be further reduced in
               future quarters as total debt has been reduced from $2.5 million
               to $300,000 today.

Because of the recurring losses over the past several years, we believe it
is important for us to manage our cash performance and assess our financial
viability based upon our ability to generate positive EBITDA, which we have
successfully done in the last three quarters ended June 30, September 30 and
December 31, 2004 in the amounts of $431,000, $619,000 and $897,000,
respectively. Among other financial measurements or models used by management
are sales forecasts, inventory forecasts, net income forecasts and cash flow
forecasts, all of which supplement the Company's EBITDA measurement.
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In the Company's filing on February 2, 2005, we highlight in footnote 1 the
limitations of using EBITDA. We will enhance our disclosures regarding our use
of EBITDA in future filings.

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. Comment: 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 statement 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.

Response: We believe that SOP 97-2 does not apply to us because our
validator and stacker products, which include software that is critical to the
operations of the products, are the focus of our sales efforts. Software is not
a significant focus of the marketing efforts or sold separately, nor is there
any contract requiring post sale software upgrades or improvements. Although the
Company capitalized significant costs in fiscal 2002 pursuant to SFAS 86, such
development and production costs of the software as a component of the costs of
the product are incidental. No such costs were capitalized in fiscal 2003, 2004
or to date in 2005.

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

3. Comment: 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.
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o    Response: While purchases of validator and stacker products are from Global
     Payment Technologies, Inc. ("GPT"), other items in Global Payment
     Technologies Pty Limited's ("GPTA") cost of sales relate to freight,
     handling charges and other expenses which were not shown as a separate line
     item and such purchases from GPT are disclosed in footnote 6 of GPTA's
     financial statements. We will comply with the requirement of Rule 4-08(k)
     by requesting the management of GPTA to include costs of revenue related to
     purchases from GPT on the face of the statement of income in future
     filings.

In addition, at your request, I am providing the following statements on
behalf of Global Payment Technologies, Inc.:

o    The Company is responsible for the adequacy and accuracy of the disclosure
     in the filing;

o    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

o    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.

Thank you very much for your comments. We trust that these responses are
sufficient for your purposes. However, if you have any further questions or
comments, please feel free to contact me at 631-231-1177 ext. 273.

Very truly yours,

Thomas McNeill
Vice President-Chief Financial Officer
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