SecProbe.io

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<FILENAME>filename1.txt
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      May 4, 2005

Mail Stop 04-09

Bruce Korman, President
1434 W. 11th Street
Los Angeles, CA 90015

Re:	Cash Technologies, Inc.
	Form 10-KSB for the year ended May 31, 2004
	Forms 10-QSB for the quarters ended August 31, 2004 and
November
30, 2004
	File No. 000-24569

Dear Mr. Korman:

We have reviewed your response letter dated March 11, 2005 and
have
the following additional comments.  As previously stated, these
comments require amendment to the referenced filings previously
filed
with the Commission.

November 30, 2004 and February 28, 2005 Forms 10-QSB
1. We have read and consider your response to comment 4. We note
that
the pro forma information that you propose to include is for the
quarter ended August 31, 2004.  As previously requested, your
November 30, 2004 Form 10-QSB should reflect the pro-forma results
of
operations required by Instruction (2)(iv) to Item 310(b) of
Regulation S-B for the periods ending November 30, 2004 and
November
30, 2003. Also, given the significance of the acquisition, amend
your
February 28, 2005 Form 10-QSB as well to include pro forma results
of
operations for the periods ending February 28, 2005 and February
28,
2004.

Form 8-K/A filed on April 22, 2005

2. Refer to note 10 to the financial statements of Tomco Auto
Products, Inc. relating to the inventory valuation. Supplementally
reconcile the significant difference between the value reported by
Tomco in its financial statements and the value you allocated to
this
inventory in your purchase accounting.

*    *    *    *

      As appropriate, please amend your Form 10-QSB for the
quarter
ending November 30, 2004 and February 28, 2005 and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental 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 amendment and responses to our comments.

      You may contact Yolanda Crittendon, Staff Accountant, at
(202)
551-3472 or the undersigned at (202) 551-3414 if you have
questions.

						Sincerely,

Jorge Bonilla
Senior Staff Accountant

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Cash Technologies, Inc.
May 4, 2005
Page 1

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