SecProbe.io

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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
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Room 4561
      November 1, 2005

Mr. Owen L. J. Jones
Chief Executive Officer
Braintech, Inc.
930 West 1st Street
Unit 102
North Vancouver, British Columbia
Canada V7P 3N4

      Re:	Braintech, Inc.
      Form 10-KSB for Year Ended December 31, 2004
		Filed March 30, 2005
      File No. 0-24911

Dear Mr. Jones,

      We have reviewed your response letter dated August 12, 2005
and
have the following comment.  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.  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 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-KSB for the Year Ended December 31, 2004

Item 7. Financial statements

Report of Independent Registered Public Accounting Firm
1. We have read your response to prior comment number 1 and note
that
the accountant`s report currently included in your Form 10-KSB for
the year ended December 31, 2004 does not comply with Article 2.02
of
Regulation S-X as the signature was inadvertently omitted from the
EDGAR submission.  Please amend your 10-KSB to include a signed
report from your independent accounting firm.

      As appropriate, please respond to this comment 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 comment 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 Stathis Kouninis, Staff Accountant, at (202)
551-3476, Mark Kronforst, Senior Staff Accountant, at (202) 551-
3451
or me at (202) 551-3489 if you have any questions regarding these
comments.

							Sincerely,

							Brad Skinner
						Accounting Branch Chief
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Mr. Owen L. J. Jones
Braintech, Inc.
November 1, 2005
Page 1

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