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CORRESP
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  Brad Skinner, Esq.

  Branch Chief, Division of Corporation Finance

  Securities and Exchange Commission

  100 F Street

  Washington, D.C. 20549

  U.S.A.

  October 3, 2005

  RE:

  TRIPLE P N.V.

  FORM 20-F FOR THE FISCAL YEAR ENDED DECEMBER 31,
  2004

  FILED JUNE 3, 2005

  FILE NUMBER 000-27346

Dear Mr. Skinner:

This is in response to the Staff’s comment letter of September 15,
2005 (the “Comment Letter”), relating to our Annual Report on Form 20-F
for the fiscal year ended December 31, 2004 (the “2004 20-F”) of Triple P N.V. (“Triple
P”, “we” or the “Company”).

Set forth below are the responses of the Company to
the Staff’s comments in the Comment Letter.
For ease of reference, each comment contained in the Comment Letter is
printed below in bold and is followed by the Company’s response.

Management’s
Discussion and Analysis, Page 8

Staff’s comment

1.                                      We note your
master-agreement with the Department of Justice in The Netherlands, which
generated approximately 28.5% of total revenues in 2004. Your disclosure on pages 4
and F-11 indicate that this agreement expired and has been temporarily extended
until July 1, 2005. Tell us whether or not this agreement has since been
renewed and if not tell us how the expiration of this agreement or portions
thereof will impact operations. If this agreement was not renewed, how do you
plan to replace this revenue stream? Tell us what consideration you have given
to discussing this agreement and the impact of its expiration on your
operations, financial position and liquidity in MD&A.

Response:

Until July 2005, the Company maintained a
master-agreement with the Department of Justice in The Netherlands, under which
more than one hundred separate entities ordered Information and Communication
Technology Systems (“ICT-systems”) from the Company. The original
master-agreement expired in September 2004 and was temporarily extended in
part until July 2005, at which time the Department of Justice split the
products and services provided under the extended master-agreement into six
separate contracts. The Company was awarded two of these new contracts.

As a result of the expiration of the master-agreement
and the receipt of the two new contracts, total expected sales to the
Department of Justice will decrease significantly from EUR 21.2M in 2004 to EUR
7.0M in 2005. Gross profit resulting from the sales to this customer will
decrease by approximately EUR 0.5M in 2005, or 4% of total gross profit for
2004.

To offset the expected impact of the loss of the
original master-agreement with the Department of Justice, in the third quarter
of 2004, the Company decided to accelerate the implementation of its strategy
of focusing on performing services with a higher gross margin and phasing out
low margin activities, as disclosed in Item 4 of the 2004 20-F.

In addition, as disclosed in Item 5 “Results of
Operations” of the 2004 20-F, cost reduction measures were taken in 2004 to
deal with the partial loss of the contract.

Based on this
strategy, the Company did not believe that the uncertainty related to the
renewal of the Department of Justice contract would result in a material effect
on the Company’s income from continuing operations, profitability, liquidity,
or capital resources.  Additionally, the
Company did not expect that the nonrenewal of the master-agreement would result
in reported financial information to cease to be indicative of future operating
results or financial condition.
Accordingly, the Company determined that the uncertainty related to the
renewal of the Department of Justice contract would be best disclosed in Item
3.D., “Risk Factors” and no separate disclosure within MD&A was provided.

FINANCIAL
STATEMENTS

Consolidated
Statements of Operations, page F-4

Staff’s comment

2.                                      We note that you do not
separately report sales and cost of sales for sales of products and services.
Explain to us why you believe this presentation complies with the requirements
of Rules 5-03(b)(1) and 5-03(b)(2) of Regulation S-X.

Response:

The Company respectfully refers the Staff to the
disclosure provided in Note 13 on page F-22 of the 2004 20-F.  In response to the Staff’s comment, the
Company will separately report sales and cost of sales of products and services
on the face of the income statement in accordance with Rules 5-03(b)(1) and
5-03(b)(2) of Regulation S-X in future 20-F filings.

Note 2
Summary of Significant Accounting Policies – Revenue Recognition, Page F-12

Staff’s comment

3.                                      For the systems
arrangements where you do not provide installation or installation is
inconsequential, your disclosure indicates that one of the revenue recognition
criteria is that title has transferred from the third party. To help us
understand your accounting in this area, provide the following supplemental
information:

•                  Tell us when the title typically transfers from the third party and to
whom it transfers;

•                  Explain how the parties involved with, and the timing of, title
transfer impacts your pattern of revenue recognition, and;

•                  Tell us whether you are reporting sales of third party hardware and
software on a gross or net basis. Provide an analysis of EITF 99-19 that
supports your presentation.

Response:

Title and risk of loss
typically transfer to the Company from its suppliers upon receipt of the
related inventory at the Company’s locations.
The Company maintains no consignment arrangements with its
suppliers.  Title and risk of loss
transfer to the Company’s customers upon acceptance by the customers at their
sites, which normally occur within one day of shipment from the Company’s
locations.

Based on our analysis of the
Company’s contracts and indicators under EITF Issue No. 99-19, “Reporting
Revenue Gross as a Principal Versus Net as an Agent”, the Company acts as a
principal in its sales transactions rather than as an agent, and therefore,
records revenues based on gross amounts received from its customers.  A discussion of the factors considered and
the impact such factors have on this conclusion follows:

The Company is the primary obligor in the
arrangement —
The Company is responsible for fulfillment, including the acceptability of the
products and services purchased by its customers.  Representations made by the Company during
its marketing efforts and the terms of the Company’s sales contracts frequently
indicate that the Company is responsible for fulfilling the ordered products
and services.

The Company has general inventory risk (before
customer order is placed or upon customer return) — As indicated above, the Company
takes title and assumes risk of loss for product inventory prior to customer
orders (that is, the Company maintains the product in inventory) and takes
title to product when it is returned by customers when the customer exercises
its right of return.  The risk of loss is
not mitigated by any of its suppliers through either the right to return unsold
products to its suppliers or inventory price protection mechanisms.

The Company has latitude in establishing price — The Company establishes the prices
it charges to its customers through sales contracts entered into with customers
independently of the Company’s suppliers.

The Company performs part of the service — Although the systems sold by the
Company are not modified, the Company performs additional services ordered by
customers. These additional services may include any combination of detailed
infrastructure design, an implementation plan for the required migration from
an existing configuration, installation and implementation services for
delivered systems.

The Company is involved in the determination of
product or service specifications — Under many sales contracts, the Company
determines the nature, type, characteristics, and specifications of the
products or services ordered by the customer.

The Company has credit risk — The Company assumes the full
credit risk for the amounts billed to its customers.  The Company must pay the amounts owed to its
suppliers after the suppliers perform, regardless of whether the Company’s
sales prices to its customers are fully collected.

Although the Company has limited discretion in supplier selection due
to the nature of the products ordered and the limited number of global
suppliers, this indicator of net reporting does not outweigh those factors
above that establish the Company as the principal and validate gross revenue reporting.

Staff’s comment

4.                                      For the systems
arrangements where you provide installation and installation is not deemed
inconsequential, your disclosure indicates that you defer revenue until all
obligations are fulfilled. Tell us how you determined that deferral of revenue
is appropriate. Tell us how

you have applied the guidance of paragraphs 63-71
of SOP 97-2 to these arrangements. As part of your response, tell us whether
you have concluded that installation services are essential to the functionality
of other elements. Explain the basis for your conclusion.

Response:

After considering the Staff’s comment and reviewing the corresponding
disclosure in the 2004 Form 20-F, the Company believes this disclosure is
being misinterpreted to imply that revenue on all systems arrangements is
deferred until completion of the installation because the installation services
do not qualify as a separate unit of accounting and are essential to the
functionality of other elements.  In
fact, as more fully described below, installation services do represent a
separate unit of accounting and are not considered to be essential to the
functionality of other elements.
Accordingly, the fair value of only these services is deferred and
recognized when installation is complete.

The Company has determined that installation services qualify as a
separate unit of accounting under EITF 00-21 because the deliverable meets the
separation criteria under paragraph 9.
Specifically, (a) the delivered items (i.e. systems including hardware
and software) have stand-alone value to the customer as systems are sold
separately by the Company’s competitors and installation can be done by any
qualified installation/service engineer, (b) there is objective and
reliable third-party evidence of the fair value of installation and (c) installation
is in the control of the Company and is considered to be probable based on the
Company’s history of performance. As a result, installation is considered a
separate unit of accounting.

The Company also believes that the installation is not inconsequential,
but does not believe that installation is essential to the functionality of the
other elements of its arrangements based on the Interpretive Response to SEC
Staff Accounting Bulletin Topic 13-A.3(c), Question 3.  The Interpretive Response to Question 3
identifies the following examples of indicators that installation is not
essential to the functionality of equipment, all of which are present in the
Company’s sales arrangements:

•              The equipment is a standard
product;

•              Installation does not
significantly alter the equipment’s capabilities; and

•              Other companies are available to
perform the installation.

Accordingly, total arrangement consideration is allocated to each
separate unit of accounting as prescribed by EITF 00-21.

Additionally, the Company has considered the guidance in paragraphs 63-71
of SOP 97-2, as interpreted by EITF Issue No. 03-05, “Applicability of
AICPA Statement of Position 97-2 to Non-Software Deliverables in an Arrangement
Containing More-Than-Incidental Software”.
Because the software included in all arrangements is off-the-shelf
software

that is not modified and the full use of the hardware is not dependent
upon the software sold by the Company, the software is not considered to be
essential to the functionality of any other element in the arrangement.  Accordingly, the arrangements offered by the
Company include no software-related elements that are required to be accounted
for under SOP 97-2.

Staff’s comment

5.                                      The disclosure regarding
of multiple element arrangements appearing under this note indicates, in part,
that you allocate revenue to each element based on its relative fair value,
provided that such element meets the criteria for treatment as a separate unit
of accounting. The disclosure also indicated that, in the absence of fair value
for undelivered items, the arrangement is accounted for as a single unit of
accounting, resulting in a delay of revenue recognition for all elements until
all systems and services are delivered. To help us understand your accounting
in this area, tell us the following:

•                  For the specific elements included in your multiple element
arrangements, explain how you determine whether service elements qualify for
accounting as separate elements;

•                  Explain whether there are circumstances or conditions, other than the
lack of fair value for undelivered elements, which result in revenue deferral;

•                  For all arrangements where revenue is deferred, clarify and explain the
basis for your revenue recognition pattern. For example, explain why revenue
for arrangements in which you lack fair value of undelivered elements is
recognized after all systems and services are delivered. Explain why this
revenue is not recognized as services are delivered.

As part of your response,
explain how you have applied pars. 63 to 71 of SOP 97-2 to these arrangements.

Response:

The Company’s multiple-element arrangements generally include any
combination of the delivery of systems, detailed infrastructure design, implementation
plans for the required migration from an existing configuration, installation
and/or implementation services for delivered systems.  The fair value for each of these deliverables
is generally readily determinable by reference to either the price of the
deliverable when it is regularly sold on a stand-alone basis or third-party
evidence of fair value (for example, prices of the Company’s or any competitor’s
largely interchangeable services in sales to similarly situated customers).

The following discussion
elaborates on the criteria in EITF 00-21 that are considered in determining
whether a separate unit of accounting exists in an arrangement with multiple
deliverables:

1.               The delivered item has value to the customer
on a stand-alone basis.

2.               There is objective and reliable evidence of
the fair value of the undelivered item(s).

3.               The arrangement does not include a general
right of return relative to the delivered item, delivery or performance of the
undelivered item(s).

With respect to the first
criterion, the Company currently sells systems separately.  In addition, each of the elements can readily
be purchased separately from numerous vendors.

With respect to the second
criterion, sufficient evidence of fair value must exist to bifurcate the
elements.  Paragraph 16 of Issue 00-21
discusses the use of fair value, stating that “The use of VSOE of fair value is
preferable in all circumstances in which it is available.  Third party evidence of fair value is
acceptable if VSOE of fair value is not available.”  The Company has determined that sufficient
evidence of the fair value of each element generally exists, based on the
availability of these services from multiple vendors in the marketplace and in
certain circumstances, actual historical pricing information of the element
when sold separately to other customers or through prices charged for renewal
periods.

With respect to the third
criterion, general rights of return relative to the delivered item are
infrequently provided.