SecProbe.io

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Room 4561
						November 15, 2005

Mr. Tim Steinkopf
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
	File No. 000-27074

Dear Mr. Steinkopf:

      We have reviewed your response letter dated October 28, 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

Consolidated Statements of Operations, page 34

1. We have read your response to prior comment number 2 and
believe
that the costs related to providing support, maintenance, training
and installation service revenues should be classified as cost of
sales.  If the individuals that provide these services play a dual
role in your operations, then an allocation of their costs should
be
considered in your income statement classification.  Refer to 5-
03(b)(2) of Regulation S-X.  As previously requested, quantify the
costs that represent the cost of providing service revenues that
are
currently included in selling and marketing expenses.  Revise your
financial statements or advise why such revision is not necessary.

Notes to Consolidated Financial Statements

Note 1.  Summary of Significant Accounting Policies

Revenue Recognition, page 37

2. We note your response to prior comment number 3 and have the
following additional comments :
a. It remains unclear to us how you determine the "average" amount
when a product or subscription is sold separately and why you
believe
this "average" represents VSOE in accordance with paragraph 10 of
SOP
97-2.  As previously requested, please describe in reasonable
detail
the process you use to determine the "average."  Explain how you
are
able to conclude that using the average amount represents VSOE
considering that the amount you charge your customers varies.
Provide us specific examples to explain how you have established
VSOE
for your elements and arrangements.
b. Please tell us more about your subscription based products.
Please tell us whether these products are licensed to your
customers
or if they are made available to your customers under a hosting
arrangement.  Clarify whether you have a continuing performance
obligation associated with the subscription based products.
Additionally, please explain why you believe it is appropriate to
recognize revenue relating to these products ratably and refer to
the
specific accounting literature that supports your revenue
recognition
model.
c. Your response indicates that VSOE of solution planning and
implementation services is determined based on the price when the
element is sold separately.  Specifically tell us how you
determine
pricing for these services.  In this regard, we note that VSOE of
services is often based on the hourly rate charged to customers.
Please provide specific examples to explain how you have
established
VSOE for these elements.
d. We note that you have not addressed our comment regarding the
circumstances in which VSOE differs from the renewal rate and/or
your
published price list.  In this regard, we note that you indicate
that
when there is no evidence of PCS being sold separately then fair
value is based on the renewal price in the support agreement.  It
would appear that such a renewal would represent evidence of PCS
being sold separately.  See paragraph 57 of SOP 97-2.  Please
advise.

	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
November 15, 2005
Page 3

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