SecProbe.io

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May 4, 2005

Mr. Brent Watson
Staff Accountant
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Mail Stop 4-06
Washington, DC 20549

Dear Mr. Watson:

We have received your letter dated May 2, 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 have read your response to prior comment 1 and note that
          you intend to enhance your disclosures regarding your use of EBITDA in
          future filings. Supplementally, provide us with your proposed
          disclosure. Based on your response, it is unclear to us whether your
          proposed disclosures will adequately address the material limitations
          associated with use of EBITDA as a performance measure. Your
          disclosures should explain how the measure is expected to be used by
          investors, identify significant factors that should be considered when
          using the measure and discuss significant trends or other information
          not captured to ensure balance and avoid undue reliance. It is also
          unclear to us whether you will adequately explain the reasons why
          management believes that EBITDA provides relevant and useful
          information to investors beyond your current disclosure that
          highlights requests from financial analysts and your competitors' use
          of the measure.

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     Response: Please read below for our suggested language to be used in our
upcoming earnings press release on Tuesday May 10, 2005 as well as the
reconciliation of net (loss) income to EBITDA.

The following is a reconciliation of EBITDA, see note 1, (in 000s) for the three
months ended:

                                       3/31/05    12/31/04    9/30/04    6/30/04
                                       -------    --------    -------    -------

Net (loss) income                       ($122)       $180       $117      ($108)

Income taxes                                2           3        (18)         -

Depreciation and amortization expense     409         468        376        392

Amortization of debt discount             356         212        110        113

Interest expense, net                      15          34         34         34
                                         ----        ----       ----       ----

  Total EBITDA                           $660        $897       $619       $431
                                         ====        ====       ====       ====

     Note 1: EBITDA is earnings before interest, taxes, depreciation and
amortization. EBITDA, which is not defined under United States generally
accepted accounting principles ("GAAP"), is presented solely as a supplemental
disclosure because management believes that it is a widely used measure of
operating performance and it is a widely accepted financial indicator used by
investors and analysts to measure performance and valuation, as well as to
provide insight into how management measures quarterly performance. EBITDA is
not intended to represent cash flows or an alternative to net income, and should
not be considered in isolation or as a substitute for a measure of performance
prepared in accordance with GAAP. Due to the recurring losses over the past
several years, the debt discount being fully amortized in the quarter ended
March 31, 2005, low levels of interest expense paid, essentially no tax expense
resulting from the Company's deferred tax position, and the reduced level of
capital expenses, management believes it is important to manage the cash
performance and assess the financial viability based upon the Company's ability
to generate positive EBITDA. 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 and are considered jointly when assessing the Company's liquidity.
Finally, the Company has significant uses of cash flows such as inventory
purchases, extended payment terms to its customers, debt principal repayments
and capital expenditures, which are not reflected in EBITDA .

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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