SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Room 4561

      June 2, 2005

John C. Harris
President and Chief Executive Officer
Viseon, Inc.
8445 Freeport Parkway, Suite 245
Irving, TX 75063

	Re:	Viseon, Inc.
		Post Effective Amendment No. 1 to Form SB-2
		Filed May 16, 2005
		File No. 333-115221

		Form 10-KSB for the Fiscal Year Ended June 30, 2004
		Form 10-QSB for the Fiscal Quarter Ended September 30,
2004
		Form 10-QSB for the Fiscal Quarter Ended December 31,
2004
		Form 10-QSB for the Fiscal Quarter Ended March 31, 2005
		File No. 00-27106

Dear Mr. Harris:

      We have reviewed your filings and have the following
comments.
Please respond to these comments within 10 business days.  Please
be
as detailed as necessary in your explanation.  In some of our
comments, we may ask you to provide us with 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 10-KSB for the Fiscal Year Ended June 30, 2004

Item 8A.  Controls and Procedures

1. You state "[t]here have been no significant changes in our
internal controls or in other factors that could significantly
affect
internal controls, nor were any corrective actions required with
regard to significant deficiencies and material weaknesses."
However, Item 308(c) requires you disclose any change in your
internal control over financial reporting that occurred during
your
last fiscal quarter that has materially affected, or is reasonably
likely to materially affect, your internal control over financial
reporting.  Please confirm that there was no change to your
internal
controls over financial reporting during the fiscal quarter ended
June 30, 2004, that had materially affected, or was reasonably
likely
to materially affect, your internal controls over financial
reporting.

Forms 10-QSB for the Fiscal Quarters Ended September 30, 2004,
December 31, 2004 and March 31, 2005

Item 3.  Controls and Procedures

2. We note you disclose in all three of your latest Forms 10-QSB
that
"due to the limited number of Company employees engaged in the
authorization, recording, processing and reporting of
transactions,
there is inherently a lack of segregation of duties."  The purpose
of
this disclosure is unclear.  Tell us if this is meant to disclose
a
material weakness or deficiency in your disclosure controls and
procedures or to disclose a change in internal controls over
financial reporting.  It appears that this disclosure is meant to
indicate that you considered a cost/benefit analysis as part of
your
evaluation as to the certitude of the effectiveness of your
processes.  If so, please confirm that your disclosure controls
and
procedures were evaluated at a reasonable assurances level and
that
your conclusion as to the effectiveness of your disclosure
controls
and procedures were at that reasonable assurances level.

*	*	*	*	*

      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 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.

	Before the amended registration statement is declared
effective
pursuant to Section 8 of the Securities Act, the company should
provide us a letter, acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert staff comments and the declaration
of
effectiveness 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 connection with our review of
your
filing or in response to our comments on your filing.

	You may contact Rebekah Toton at (202) 551-3857 or me at
(202)
551-3462 if you have any questions regarding these comments.

								Sincerely,

								Mark P. Shuman
								Branch Chief - Legal

cc:	Via Facsimile (214) 922-4144
	Lance M. Hardenburg, Esq.
	Hallett & Perrin, P.C.
	Telephone: (214) 922-4156
??

??

??

??

John C. Harris
Viseon, Inc.
June 2, 2005
Page 1

</TEXT>
</DOCUMENT>