SecProbe.io

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April 26, 2005

VIA EDGAR AND FEDERAL EXPRESS

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Mail Stop 0306
Washington, D.C. 20549

Attention:  Mr. N. Jay Webb

Re:      Young Innovations, Inc.
         Form 10-K for the year ended December 31, 2004
         Filed March 7, 2005
         File No. 000-23213

Gentlemen:

This letter is provided to you on behalf of Young Innovations, Inc. ("Young") in
respect to the written comments received from the Division of Corporation
Finance dated March 24, 2005, with regard to the above referenced Form 10-K. For
your convenience and ease of use, we have set forth each of the Staff's comments
in italics, followed by Young's responses in bold type.

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 of
          operations for all periods presented, if material.

          TO THE EXTENT APPLICABLE, WE INTEND TO APPLY THESE DISCLOSURE COMMENTS
          IN FUTURE FILINGS BEGINNING WITH YOUNG'S FORM 10-Q FOR THE QUARTER
          ENDING MARCH 31, 2005, AND ITS FORM 10-K FOR THE YEAR ENDING DECEMBER
          31, 2005.

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          WITH RESPECT TO THE SUPPLEMENTAL INFORMATION YOU REQUESTED, THE SALES
          INCENTIVE PROGRAMS THAT WERE RESTRUCTURED BY YOUNG, AND SUBSEQUENTLY
          REFERENCED ON PAGE 17 OF OUR FORM 10-K, PRINCIPALLY CONSISTED OF
          OFF-INVOICE PRICING DISCOUNTS (I.E., A DISCOUNT REFLECTED DIRECTLY ON
          THE BILLING AND REQUIRING NO PERFORMANCE OBLIGATION ON THE PART OF THE
          CUSTOMER) THAT ARE RECORDED IN THE NET SALES ACCOUNT AT THE TIME OF
          SALE. DURING THE SECOND QUARTER OF 2004, YOUNG ELIMINATED CERTAIN OF
          THESE PROMOTIONAL PRICING INCENTIVES, WHICH REDUCED CUSTOMER ORDERS
          AND SALES IN THAT QUARTER. THE BUSINESS REASON FOR THIS SECOND QUARTER
          CHANGE WAS TO TRANSITION TO PRODUCT LINE BASED PRICING PROMOTIONS FROM
          THE BRAND BASED PROMOTIONS THAT HAD BEEN RUN IN PREVIOUS PERIODS.
          THESE CHANGES WERE MADE TO FACILITATE CERTAIN NEW PRODUCT
          INTRODUCTIONS AND FACILITIES CONSOLIDATION EFFORTS, WHILE PROVIDING
          FOR IMPROVED SERVICE LEVELS TO YOUNG'S DISTRIBUTORS.

         IN ADDITION TO THE PRICING PROMOTIONS MODIFIED IN 2004, YOUNG EMPLOYS A
         VARIETY OF OTHER PROMOTIONAL ACTIVITIES, INCLUDING, BUT NOT LIMITED TO,
         REBATE PROGRAMS, FREE GOODS OFFERS AND FREE SHIPPING PROMOTIONS. THESE
         ACTIVITIES AND PROGRAMS DID NOT SIGNIFICANTLY CHANGE IN 2004 AS
         COMPARED TO PRIOR YEARS. YOUNG'S INCOME STATEMENT CLASSIFICATION AND
         EXPENSE RECOGNITION AND MEASUREMENT FOR THESE PROMOTIONAL ACTIVITIES IS
          IN ACCORDANCE WITH THE PROVISIONS OF EITF 01-9: ACCOUNTING FOR
         CONSIDERATION GIVEN BY A VENDOR TO A CUSTOMER (INCLUDING A RESELLER OF
         THE VENDOR'S PRODUCTS).

     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.

          TO THE EXTENT APPLICABLE, WE INTEND TO APPLY THESE DISCLOSURE COMMENTS
          IN FUTURE FILINGS BEGINNING WITH YOUNG'S FORM 10-Q FOR THE QUARTER
          ENDING MARCH 31, 2005, AND ITS FORM 10-K FOR THE YEAR ENDING DECEMBER
          31, 2005.

          WITH RESPECT TO THE SUPPLEMENTAL INFORMATION YOU REQUESTED, YOUNG
          OFFERS CERTAIN PURCHASERS OF OUR PANORAMIC X-RAY EQUIPMENT, THE
          OPPORTUNITY TO FINANCE THEIR PURCHASE WITH A NOTE PAYABLE TO YOUNG.
          YOUNG HAS HISTORICALLY OFFERED VARIOUS FINANCING OPTIONS TO ITS
          CUSTOMERS, INCLUDING NOTES PAYABLE TO YOUNG AND FINANCING THROUGH
          THIRD PARTIES. IN 2004, THE PROPORTION OF NOTES FINANCED BY YOUNG
          VERSUS THOSE FINANCED BY THIRD PARTIES INCREASED. THESE TRANSACTIONS
          ARE RECORDED AS A SALE UPON THE TRANSFER OF TITLE TO THE PURCHASER,
          WHICH GENERALLY OCCURS AT THE TIME OF SHIPMENT, AT AN AMOUNT EQUAL TO
          THE SALES PRICE OF NON-FINANCED SALES. INTEREST ON THESE NOTES IS
          ACCRUED AS EARNED AND RECORDED AS INTEREST INCOME. FOR THE YEARS ENDED

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          DECEMBER 31, 2004, 2003 AND 2002, THE TOTAL X-RAY EQUIPMENT NET SALES
          THAT WERE MADE UNDER YOUNG'S EQUIPMENT FINANCING PROGRAM TOTALED
          $4,215, $1,234, AND $279 ($ IN THOUSANDS). TOTAL NET SALES OF X-RAY
          EQUIPMENT (I.E., ALL SALES INCLUDING YOUNG-FINANCED FINANCED SALES)
          FOR THE YEARS ENDED DECEMBER 31, 2004, 2003 AND 2002 WERE $10,942,
          $10,485 AND $9,563, RESPECTIVELY ($ IN THOUSANDS).

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.

          TO THE EXTENT APPLICABLE, WE INTEND TO APPLY THESE DISCLOSURE COMMENTS
          IN FUTURE FILINGS BEGINNING WITH YOUNG'S FORM 10-Q FOR THE QUARTER
          ENDING MARCH 31, 2005, AND ITS FORM 10-K FOR THE YEAR ENDING DECEMBER
          31, 2005. WITH RESPECT TO THE SUPPLEMENTAL INFORMATION REQUESTED,
          THERE WERE NO POTENTIAL CONTINGENT PAYMENTS OUTSTANDING WITH RESPECT
          TO THE OBTURA SPARTAN TRANSACTION, OR ANY OTHER ACQUISITION, AT
          DECEMBER 31, 2004.

     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.

          BASED UP OUR CALCULATIONS PERFORMED IN ACCORDANCE WITH THE GUIDANCE
          OUTLINED IN RULE 1-02(W)(3), AND SUPPLEMENTALLY IN RULE 3-05(B)(2)(I)
          AND RULE 11-01(B)(1), AS PROVIDED BELOW, WE DETERMINED THAT HISTORICAL
          AND PRO FORMA FINANCIAL STATEMENTS FOR OBTURA SPARTAN WERE NOT
          REQUIRED IN THE 8-K FILED ON DECEMBER 5, 2003.

          1-02(W)(1) TEST - PURCHASE PRICE MUST BE LESS THAN 20% OF TOTAL ASSETS

               o    PURCHASE PRICE = $12,572,000 + POTENTIAL EARNOUT
                    ($2,000,000) = $14,572,000 (PER 2003 10-K)

               o    TOTAL ASSETS FOR YOUNG PRE-ACQUISITION = $84,988,000 (AS OF
                    12/31/02 - PER FORM 10-K)

               o    PURCHASE PRICE/TOTAL ASSETS = 17.1%
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          1-02(W)(2) TEST - TOTAL ASSETS ACQUIRED MUST BE LESS THAN 20% OF TOTAL
          ASSETS

               o    OBTURA SPARTAN ASSETS ACQUIRED = $4,177,000

               o    TOTAL ASSETS FOR YOUNG PRE ACQUISITION = $84,988,000 (AS OF
                    12/31/02 - PER FORM 10-K)

               o    OBTURA SPARTAN ASSETS/TOTAL ASSETS = 4.9%

          1-02(W)(3) TEST - INCOME FROM CONTINUING OPERATIONS BEFORE INCOME
          TAXES, EXTRAORDINARY ITEMS AND CUMULATIVE EFFECT OF A CHANGE IN
          ACCOUNTING PRINCIPLE FOR ACQUIRED BUSINESS MUST BE LESS THAN 20% OF
          SUCH INCOME FOR YOUNG FOR THE MOST RECENTLY COMPLETED FISCAL YEAR
          (2002)

               o    OBTURA SPARTAN INCOME FROM CONTINUING OPERATIONS (2002) =
                    $1,663,000

               o    YOUNG INCOME FROM CONTINUING OPERATIONS (2002) = $18,712,000
                    (AS OF 12/31/02 PER FORM 10-K)

               OBTURA SPARTAN OPERATING INCOME/YOUNG OPERATING INCOME = 8.9%

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.

          TO THE EXTENT APPLICABLE, WE INTEND TO APPLY THESE DISCLOSURE COMMENTS
          IN FUTURE FILINGS BEGINNING WITH YOUNG'S FORM 10-Q FOR THE QUARTER
          ENDING MARCH 31, 2005, AND ITS FORM 10-K FOR THE YEAR ENDING DECEMBER
          31, 2005.

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."

               o    By including the language "in all material respects" after
                    the word "effective" in your current disclosure, it does not

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                    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.

          TO THE EXTENT APPLICABLE, WE INTEND TO APPLY THESE DISCLOSURE COMMENTS
          IN FUTURE FILINGS BEGINNING WITH YOUNG'S FORM 10-Q FOR THE QUARTER
          ENDING MARCH 31, 2005, AND ITS FORM 10-K FOR THE YEAR ENDING DECEMBER
          31, 2005.

               o    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).

          TO THE EXTENT APPLICABLE, WE INTEND TO APPLY THESE DISCLOSURE COMMENTS
          IN FUTURE FILINGS BEGINNING WITH YOUNG'S FORM 10-Q FOR THE QUARTER
          ENDING MARCH 31, 2005, AND ITS FORM 10-K FOR THE YEAR ENDING DECEMBER
          31, 2005.

     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."

               o    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.

          TO THE EXTENT APPLICABLE, WE INTEND TO APPLY THESE DISCLOSURE COMMENTS
          IN FUTURE FILINGS BEGINNING WITH YOUNG'S FORM 10-K FOR THE YEAR ENDING
          DECEMBER 31, 2005.

               o    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

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                    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.

          TO THE EXTENT APPLICABLE, WE INTEND TO APPLY THESE DISCLOSURE COMMENTS
          IN FUTURE FILINGS BEGINNING WITH YOUNG'S FORM 10-Q FOR THE QUARTER
          ENDING MARCH 31, 2005, AND ITS FORM 10-K FOR THE YEAR ENDING DECEMBER
          31, 2005.

Young acknowledges that:

               o    Young is responsible for the adequacy and accuracy of the
                    disclosures in this 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    Young 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.

Please contact me directly with any questions at (312) 644-6400 extension 107.

Best Regards,

/s/ Christine R. Boehning

Christine R. Boehning
Chief Financial Officer

Cc:      Tom Dyer

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