SecProbe.io

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March 24, 2005

Mail Stop 0306

Ms. Christine R. Boehning
Vice President and CFO
Young Innovations, Inc.
13705 Shoreline Court East
Earth City, MO 63045

	RE:	Young Innovations, Inc.
		Form 10-K for the Fiscal Year Ended December 31, 2004
		File No. 000-23213

Dear Ms. Boehning:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents. Where indicated, we think you should revise your future
filings 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 10-K for the Fiscal Year December 31, 2004

Note 2. Summary of Significant Accounting Policies

Revenue Recognition - Page 28

1. We note on page 17 that the increase in fiscal 2004 sales was
offset by a reduction in second quarter sales resulting from the
restructuring of sales incentive programs to dealers, and further
on
page 17 that fiscal 2003 sales benefited from a strong response to
promotional activity.  Please tell us supplementally and revise
future filings to describe the nature of the promotional
activities,
how you account for the activities, and the impact to the
statements
operations for all periods presented, if material.
2. We note on page 18 and in Note 6 to the financial statements
that
you offer certain customers the opportunity to participate in an
equipment financing program, and it appears that the sales under
this
program have increased in fiscal 2004.  Please tell us
supplementally
and revise future filings to describe your equipment financing
program, how you account for sales under the program, and the
amount
of revenue recorded from financed sales in all periods presented,
if
material.

Note 3. Acquisitions - Page 31

3. Please revise future filings to include the disclosures
required
by paragraphs 51(b), 51(f), 52(c)(1) and 54 of SFAS 141 related to
your acquisition of Obtura Spartan.  Additionally, please tell us
supplementally and revise the MD&A in future filings to discuss
the
status of any contingent payments associated with this
acquisition.
4. We note that you did not provide historical and pro forma
financial statements of Obtura Spartan along with your 8-K filed
December 5, 2003.  Please supplementally provide us with the
calculations outlined at Rule 1-02.w.3 of Regulation S-X for this
acquisition.  We may have further comments after reviewing your
response.

Note 10. Goodwill and Other Intangible Assets - Page 34

5. Please revise future filings to include a rollforward of
goodwill
to describe the changes in the carrying amount of goodwill for the
current year and the prior year in accordance with paragraph 45(c)
of
SFAS 142.

Item 9A. Controls and Procedures - Page 42

6. We note that your "Chief Executive Officer and Chief Financial
Officer have concluded, based on their evaluation as of the end of
the period covered by this report, that our disclosure controls
and
procedures are effective in all material respects in ensuring that
information required to be disclosed in the reports that we file
or
submit under the Securities Exchange Act of 1934 is recorded,
processed, summarized and reported, within the time periods
specified
in the Securities and Exchange Commission`s rules and forms."
* By including the language "in all material respects" after the
word
"effective" in your current disclosure, it does not appear that
your
certifying officers have reached a conclusion that your disclosure
controls and procedures are effective.  Please revise this
disclosure
in future filings to address your officers` conclusions regarding
the
effectiveness of your disclosure controls and procedures.
* Revise your disclosure in future filings to clarify, if true,
that
your officers concluded that your disclosure controls and
procedures
are also effective to ensure that information required to be
disclosed in the reports that you file or submit under the
Exchange
Act is accumulated and communicated to your management, including
your chief executive officer and chief financial officer, to allow
timely decisions regarding required disclosure.  See Exchange Act
Rule 13a-15(e).
7. We note your disclosure that "there have been no significant
changes to our internal controls over financial reporting or in
other
factors that could significantly affect these controls subsequent
to
the date of the previously mentioned evaluation."
* In future filings, please revise your disclosure concerning
changes
in your internal control over financial reporting to also indicate
whether there was any change in your internal control over
financial
reporting that occurred during the fourth quarter that has
materially
affected or is reasonably likely to materially affect your
internal
control over financial reporting, as required by Item 308(c) of
Regulation S-K as amended effective August 13, 2003.
* We note your disclosure that "there have been no significant
changes in internal control over financial reporting or in other
factors that could significantly affect these controls..."  In
future
filings, please remove the words "significant" and "or in other
factors that could significantly affect", and revise your
disclosure
to discuss all changes in your internal control over financial
reporting that have materially affected, or that are reasonably
likely to materially affect, your internal control over financial
reporting, as required by Item 308(c) of Regulation S-K, as
amended
effective August 13, 2003.

*    *    *    *

       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 with your response that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  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 Tom Dyer, Staff Accountant, at (202) 824-5564 or
me
at (202) 942-1812 if you have any questions.  In this regard, do
not
hesitate to contact Daniel Gordon, Branch Chief, at (202) 942-
2813.

      Sincerely,

							N. Jay Webb
							Reviewing Accountant

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Ms. Christine R. Boehning
Young Innovations, Inc.
March 24, 2005
Page 1 of 5

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