SecProbe.io

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Room 4561
						August 25, 2005

Mr. John E. McNulty
Chairman, President and
Chief Executive Officer
Secure Computing Corporation
4810 Harwood Road
San Jose, CA 95124

Re:	Secure Computing Corporation
	Form 10-K for Fiscal Year Ended December 31, 2004
	Filed March 11, 2005
      Form 10-Q for Fiscal Quarter Ended June 30, 2005
	Filed August 3, 2005
	File No. 000-27074

Dear Mr. McNulty:

      We have reviewed the above referenced filings and have the
following comments.  Please note that we have limited our review
to
the matters addressed in the comments below.  We may ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please be as detailed as necessary in your
explanation.  After reviewing this information, we may 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 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 Ended December 31, 2004

Financial Statements

Consolidated Balance Sheets and Consolidated Statements of Cash
Flows, pages 33 and 36

1. We note that you have reclassified certain amounts on your
balance
sheet and statement of cash flows for the period ended December
31,
2003 and that these reclassifications appear to be related to
auction
rate securities.  The reclassification appears to have had a
quantitatively material effect on your statement of cash flows but
we
note that you have not included specific disclosure regarding this
reclassification and why it was made.  Tell us more about this
reclassification and explain to us why you did not believe
disclosure
was necessary.

Consolidated Statements of Operations, page 34

2. We note that you derive revenue from security and support
services.  To the extent service revenue is material, tell us how
you
considered Rules 5-03.1 and 5-03.2 of Regulation S-X with regards
to
your income statement presentation.

Notes to Consolidated Financial Statements

Note 1.  Summary of Significant Accounting Policies

Revenue Recognition, page 37

3. You disclose that revenue from products is recognized when
persuasive evidence of an arrangement exists, delivery has
occurred,
the fee is fixed or determinable, and collection is probable.
This
disclosure is general in nature and does not specifically address
when revenue is recognized.  Please tell us how you determine when
each of your revenue recognition criteria has been met for product
sales (i.e., licenses and hardware).  Also, please explain to us
when
revenue from royalty arrangements is recognized.

4. Your disclosure indicates that you determine evidence of fair
value based on "the approved price list and discount schedule and
the
actual prices charges for comparable arrangements."  Explain to us
how this represents vendor-specific objective evidence of fair
value
as defined by paragraph 10 of SOP 97-2.  Explain why you believe a
"comparable arrangement" is sufficient to establish VSOE of fair
value for each element in an arrangement. As part of your
response,
describe how you determine VSOE for PCS and any other undelivered
elements, particularly where you apply the residual method.
Explain
any circumstances under which VSOE for PCS differs from either the
renewal rate and/or your published price lists.

5. We note your disclosure regarding the use of sell-through
reporting for your "Safeword for Citrix" products.  Please tell us
whether you use sell-through reporting for all distributor or
reseller sales or just for "Safeword for Citrix" sales.  As part
of
your response, tell us about any return, price protection,
rotation
or similar rights you offer to your resellers or distributors.
Explain how your revenue recognition policy disclosures reflect
any
such rights.

6. We note disclosure on page 38 that you have unbilled
receivables.
Tell us more about the arrangements that result in these unbilled
receivables and tell us how you have considered the collectibility
criteria and/or the fixed or determinable criteria within
paragraph 8
of SOP 97-2 when recognizing revenue.  Tell us when they typically
become billable and address the extent to which you have
successfully
billed and collected these amounts subsequent to the balance sheet
date.

Form 10-Q for the Fiscal Quarter Ended June 30, 2005

Item 4. Controls and Procedures, page 14

7. We note your disclosure that your "Chief Executive Officer and
Chief Financial Officer, concluded that as of June 30, 2005, our
disclosure controls and procedures were effective at the
reasonable
assurance level to ensure that information required to be
disclosed
in the Quarterly Report of Form 10-Q was recorded, processed,
summarized and reported within the time periods required by the
Securities and Exchange Commission`s rules and forms."  Tell us
how
your officers considered Exchange Act Rule 13a-15(e) concluding
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.

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and 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 Christine Davis, Staff Accountant, at (202)
551-
3408, Lisa Mitrovich, Assistant Chief Accountant at (202) 551-3453
or
me at (202) 551-3489 if you have questions regarding these
comments.

Sincerely,

      Brad Skinner
							Accounting Branch Chief
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Mr. John E. McNulty
Secure Computing Corporation
August 25, 2005
Page 4

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