SecProbe.io

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Mail Stop 4561

          July 12, 2005

      VIA USMAIL and FAX (303) 238-3368

Mr. Michael I. Ruxin, M.D.
Acting Chief Financial Officer
Global Med Technologies, Inc.
12600 West Colfax, Suite C-420
Lakewood, Colorado 80215

      Re:	Global Med Technologies, Inc.
		Form 10-K for the year ended 12/31/2004
      Filed 3/4/2005
      File Nos. 000-22083

Dear Mr. Michael I. Ruxin, M.D.:

      We have reviewed your filing and have the following comment.
We have limited our review to only the issues addressed below and
will make no further review of your document.  As such, all
persons
who are responsible for the adequacy and accuracy of the
disclosure
are urged to be certain that they have included all information
required pursuant to the Securities Exchange Act of 1934.

      Where indicated, we think you should revise your document in
response to this comment.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In our comment, we may ask you to provide us with information so
we
may better understand your disclosure.  After reviewing this
information, we may or may not 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 disclosures in your
filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on 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 YEAR ENDED DECEMBER 31, 2004

Financial Statements and Notes

Note 1 - Summary of Significant Accounting Policies

Revenue Recognition, pages F-15 - F-16

1. We note that when the consulting services are essential to the
functionality of the product or any portion of the payment of the
license fee is contingent solely upon the performance of
consulting
services, license fees are recognized ratably over the anticipated
period of performance of the consulting services.   Please define
"ratably" and tell us how you considered the guidance outlined in
paragraph 64 of SOP 97-2 in determining the appropriateness of
your
revenue recognition policy.

*    *    *    *

      As appropriate, respond to this comment within 10 business
days
or tell us when you will provide us with a response.  Please
furnish
a cover letter that keys your response to our comment and provides
any requested information.  Detailed cover letters greatly
facilitate
our review.  Please file your cover letter on EDGAR.  Please
understand that we may have additional comments after reviewing
your
response to our comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings 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 comment, 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

	You may contact Wilson K. Lee, at (202) 551-3468 or me, at
(202)
551-3498 if you have questions.

							    Sincerely,

    Linda Van Doorn
    Senior Assistant Chief Accountant

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Michael I. Ruxin, M.D.
Global Med Technologies, Inc.
July 12, 2005
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