SecProbe.io

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Room 4561
						September 14, 2005

Mr. Tim Steinkopf
Chairman, President and
Chief Financial Officer and
Senior Vice President
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. Steinkopf:

      We have reviewed your response letter dated August 31, 2005
and
have the following additional comments.  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 your response to prior comment number 1.  Please
provide
further support for why you believe specific disclosure of the
reclassification was not necessary.  As part of your response,
tell
us how you considered SAB 99 and paragraph 2 of Chapter 2A of ARB
43.

Consolidated Statements of Operations, page 34

2. You indicate in your response to prior comment number 2 that in
future filings you will separately disclose on the income
statement
revenue derived from products and services.  Your response does
not
appear to address how you will disclose the related cost of sales.
As previously requested, tell us how you have considered Rule 5-
03.2
of Regulation S-X.

Notes to Consolidated Financial Statements

Note 1.  Summary of Significant Accounting Policies

Revenue Recognition, page 37

3. We note your response to prior comment number 3 regarding your
royalty arrangements.  You indicate that revenue from these
arrangements is recognized at the time the P.O. or royalty report
is
received.   Explain to us your basis for recording revenue at the
time of the P.O.   As part of your response, tell us whether the
P.O.
provides evidence of shipment by the OEM.  You also indicate that
when a royalty report is not received until the period after the
revenue is earned you accrue revenue based on evidence of shipment
provided by the OEM.    Please tell us more about the "evidence of
shipment" provided by your OEM and tell us whether you have had to
record adjustments to revenue related to any differences between
this
evidence and the royalty report you subsequently receive.  Also,
please explain to us why you believe disclosure of your revenue
recognition for these royalty arrangements is not necessary.

4. We note your response to prior comment number 4.  It does not
appear that you have addressed how you determine VSOE for each
element in a multiple-element arrangement, specifically the
undelivered elements when you use the residual method.  Also,
please
explain any circumstances under which VSOE for PCS differs from
either the renewal rate and/or your published price lists.

5. You indicate in your response to prior comment number 5 that
you
use sell-through reporting for all distributor and reseller sales.
We note that your current disclosure does not appear to reflect
such
policy.  Also, please explain to us how and when you typically
receive evidence of end-user sell-through and how you have
considered
disclosing such information.

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

Item 4. Controls and Procedures, page 14

6. Your response to prior comment number 7 indicates that "our
disclosure controls and procedures are effective to ensure that
information required to be disclosed in the reports that we file
or
submit under the Exchange Act is accumulated and communicated to
our
management, including CEO and CFO, to allow timely decisions
regarding required disclosure."  Please tell us how you considered
disclosing such conclusion as required by Exchange Act Rule 13a-
15(e).

	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.

	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. Tim Steinkopf
Secure Computing Corporation
September 14, 2005
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