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Letter of correspondence

 SECURE COMPUTING CORPORATION

 4810 Harwood Road

 San Jose, CA 95124

 PRIVILEGED AND CONFIDENTIAL

 SUBMITTED VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 Washington, D.C. 20549

 Attn: Christine Davis

Re:
Secure Computing Corporation

 Response to SEC
Review Comments dated 8/25/05

 Commission file no: 000-27074

 Dear Gentlemen:

 This letter is in response to a letter dated August 25, 2005 to Secure Computing Corporation regarding Secure’s Form 10-K for fiscal year ended
December 31, 2004 and Form 10-Q for fiscal quarter ended June 30, 2005 (Commission File No. 000-27074). The following responses are keyed to the Staff’s comments.

 Form 10-K for the Fiscal Year Ended December 31, 2004

 Financial Statements

 Consolidated Balance Sheets and Consolidated Statement of Cash Flows, pages 33 and 35

 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.

 The reclassification of the auction rate securities was due to heightened awareness of the contractual maturities of the auction rate
securities based on the SEC and PCAOB raising questions in early 2005 on investors’ balance sheet classification and statement of cash flows presentation of auction rate securities. Although auction rate securities are frequently re-priced (90
days or less), we learned that these instruments cannot be classified as cash equivalents under FASB Statement No. 95, Statement of Cash Flows

 due to the contractual maturities of the auction rate securities being longer than 90 days. Therefore, we reclassified
the auction rate securities balance as of December 31, 2003 to short-term investments from cash. We did not specifically make a disclosure regarding this reclassification as our overall liquidity of these instruments did not change, the market value
of the reclassified instruments approximated cost, and the readers of the financial statements look at the total of cash, cash equivalents and short-term investments when reviewing a company’s liquidity. Our short-term investments are highly
liquid in nature and the reclassification did not impact our liquidity or the short-term availability of these funds which are invested in auction rate securities. We also state in our Summary of Significant Accounting Policies on page 37 that
certain previously reported amounts have been reclassified to conform to the current presentation format with no impact on net income (loss).

 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.

 Secure
Computing has consistently taken the position that providing separate disclosure of products and services revenue provides no additional value to the reader of the income statements because our services revenue is so closely tied to our product
revenue. Our services revenues include support and maintenance of our products, as well as training and installation of our products. However, even though we do not believe that there is a useful distinction between product and service revenue, in
future filings we will separately disclose revenue derived from products and services on the face of the financial statements. We supplementally advise the Staff that the breakdown between products and services revenue for the years ended December
31, 2002, 2003 and 2004 are as follows (in ‘000s):

12/31/02

12/31/03

12/31/04

 Products

$
37,604 or 61
%

$
52,421 or 69
%

$
67,625 or 72
%

 Services

$
24,356 or 39
%

$
23,792 or 31
%

$
25,753 or 28
%

 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.

 2

 Secure Computing recognizes revenue from products when (1) persuasive evidence of an arrangement exists, (2) delivery has
occurred, (3) the fee is fixed or determinable, and (4) collection is probable. The following describes how the company determines when each of these criteria has been met for product sales:

 (1) Persuasive evidence - Larger licensing transactions are evidenced by a contract
containing standard terms and conditions approved by the Company’s General Counsel or designee and signed by both parties. For certain geographies, smaller transactions are documented by a written contract. All other arrangements require a
valid purchase order or on-line authorization in the form normally issued by the customer, evidencing the customer’s commitment to receive and pay for product and/or services. If the customer is purchasing through a reseller arrangement, the
reseller will be ordering by a PO that is documented by a signed Master Reseller Agreement, which includes necessary content for the P.O. We use sell-through reporting for all distributor and reseller sales and recognize revenue only at the point
that we have end-user sell-through data.

 (2) Delivery has occurred -
For products sold “FOB origin”, delivery occurs at the time of physical shipment of the product. For products sold “FOB destination”, delivery occurs at the time of physical delivery to the customer. If a licensing agreement
provides a customer with the right to multiple copies of a software product in exchange for a fixed fee, delivery occurs upon the transfer of the product master, or the first copy of the product if the master is not to be transferred (prior transfer
of an evaluation copy of the software qualifies as delivery provided the evaluation copy contains equivalent functionality to the product in the contract or PO). When software is delivered electronically, delivery is met when either the customer
takes possession of the software via a download or the company provides the customer with the necessary access codes to immediately take possession of the software. In a multiple element arrangement, delivery is not considered to have occurred for
an element if there are undelivered elements that are essential to the functionality of the delivered element because the customer would not have the full use of the delivered element.

 (3) The fee is fixed or determinable when the arrangement is for a set amount that is not subject to refund or adjustment and is on a
known and fixed schedule. Extended payment terms may indicate that the fee is not fixed or determinable. If payment of a significant portion of the fee is not due until expiration of the agreement or more than 12 months after delivery, the licensing
fee is presumed not to be fixed and revenue is not recognized until the payments become due. Payment terms under 12 months but outside normal customary terms (our standard terms are 30 days) are evaluated as to their effect on the fee being fixed or
determinable. Secure Computing does not have a history of granting concessions to its customers.

 (4) Collection must be probable for revenue to be recognized. If collection from a customer is not probable, revenue will be recognized when the payments are due and the collection is guaranteed by a
creditworthy third party such as a parent company guarantee, issuance of a standby letter of credit or collection of the cash. In determining credit-worthiness of new accounts, we use several resources including D&B reports and

 3

 public filings with the SEC. Prior to a first order being received from a new reseller customer we have a process in
place to ensure that we have received a completed credit application, a reseller application and a signed reseller contract. Credit lines and credit file information are reviewed and adjusted periodically to ensure that credit levels extended remain
justified.

 Revenue from royalty arrangements is recognized at the time
the P.O. or royalty report is received from our OEM partner. When we do not receive the royalty report until after the period the revenue was earned, we accrue the revenue into the proper period based on evidence of shipment within the period,
provided by the OEM partner. Persuasive evidence of an arrangement exists because our OEM partners are required to have a current OEM agreement in place. Delivery has occurred because Secure Computing has transferred ownership of the product master
or development kit (which the OEM partner has taken and built into their technology) prior to our receipt of a valid P.O. or royalty report and we have no further obligations following the transfer of ownership. The fee is fixed and determinable
based on the pricing schedules included in the OEM partner agreements and the purchases are for a specific number of users. Secure Computing has a history of successfully collecting fees under the original payment terms without making subsequent
concessions.

 We respectfully submit to the Staff that the revenue recognition
disclosure provided in our Form 10-K is sufficiently specific and that additional disclosure would not be useful to the readers of the financial statements.

 4. Your disclosure indicates that you determine evidence of fair value based on “the approved price list and discount schedule and
the actual prices charged 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 of 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.

 Secure Computing allocates revenue to the various elements of a multiple element arrangement based on the fair value of each element sold. We determine the fair value of
each element based on its selling price when sold separately. We indicate that the evidence of fair value is based on the approved price list and discount schedule and the actual prices charged for comparable arrangements. A “comparable
arrangement” means the price normally charged for the product or service when the customer has purchased a like number of licenses, which reiterates our previous statement that the fair value is determined using the price charged for the
element when sold separately. Since this language is redundant, we will remove the language referring to “comparable arrangements” in future filings.

 4

 Vendor specific objective evidence for PCS, and any other undelivered elements, is determined based on the price the
customer will be required to pay when the PCS arrangement is sold separately. If there is not evidence of the PCS being sold separately, then the fair value is determined based on the customer’s renewal pricing as evidenced in their customer
support agreement.

 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 such rights.

 We use sell-through reporting for all distributor and reseller sales and recognize revenue
only at the point that we have end-user sell-through data.

 Our current policy
is that our distributors/resellers are not allowed to hold inventory (with the exception of “Safeword for Citrix” products as disclosed on page 38), and therefore, there are no return, price protection, rotation, or similar rights provided
to resellers and distributors, including those that hold Safeword for Citrix inventory. At 12/31/04 the balance of the Safeword for Citrix product being held as inventory by foreign resellers totaled $187,882.

 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.

 Unbilled receivables represents the asset we have related to ‘future dated sales orders’ and ‘revenue accruals’.

•

Future dated sales orders – These arrangements arise when a customer has placed an order for subscription or support services but has requested to be billed on a
periodic basis. For example, a P.O. that has been received for an annual subscription but is being billed on a quarterly basis, in the future. The revenue related to this order is recorded as deferred revenue and is recognized over the life of the
contract. Secure Computing has a history of successfully collecting fees under the original payment terms without making subsequent concessions.

•

Revenue accruals - When we do not receive the OEM royalty report until after the period the revenue was earned, we accrue the revenue into the proper period based on evidence
of shipment within the period. The billing for this revenue occurs subsequently, when the OEM report is received. The fee is fixed and determinable based on the pricing schedules included in the OEM

 5

 partner agreements. Secure Computing has a history of successfully collecting fees under the original
payment terms without making subsequent concessions.

 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.

 Our officers concluded 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 disclosu