SecProbe.io

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Mail Stop 0306

May 19, 2005

Via Facsimile and U.S. Mail

Mr. Dave Lubbe
Chief Financial Officer
Orbit/FR, Inc.
506 Prudential Road
Horsham, PA 19044

	Re: 	Orbit/FR, Inc.
		Form 10-K for the year ended December 31, 2004
      SEC File No. 0-22583

Dear Mr. Lubbe:

      We have reviewed your filing and have the following
comments.
We have limited our review to matters related to the issues raised
in
our comments.  Where indicated, we think you should revise your
filing in response to these comments.  If you disagree, we will
consider your explanation as to why our comments are inapplicable
or
a revision is unnecessary.  Please be as detailed as necessary in
your explanation.  In some of our comments, we may ask you to
provide
us with supplemental 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 disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments 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

Item 9A. Controls and Procedures - Page 26

1. Please respond to the following comments regarding your
disclosure:

a. We note your disclosure under Item 9B, "Other Information," on
page 27, that you inadvertently failed to file your December 31,
2004
press release on Form 8-K. In light of this fact, disclose in
reasonable detail the basis for your officers` conclusions that
the
company`s disclosure controls and procedures were nonetheless
effective as of the end of the period covered by the report.

b. We note your disclosure that management concluded as of the
evaluation date that your disclosure controls and procedures were
"...effective to ensure that material information relating to the
Company would be made known to them by others within the Company,
particularly during the period in which this annual report was
being
prepared."  Please note that all language that appears following
the
word "effective" must be consistent with the language that appears
in
the definition of "disclosure controls and procedures" set forth
in
Rule 13a-15(e) of the Exchange Act. Revise your disclosure to
clarify
whether your Chief Executive Officer and Chief Financial Officer
concluded that your disclosure controls and procedures are
effective
to ensure that information required to be disclosed in the reports
you file or submit under the Exchange Act is recorded, processed,
summarized and reported within the time periods specified in the
Commission`s rules and forms, and that it is accumulated and
communicated to management, including your Chief Executive Officer
and Chief Financial Officer, as appropriate to allow timely
decisions
regarding required disclosure.  Please similarly revise future
filings.

c. Please revise your disclosure concerning changes in your
internal
control over financial reporting to also indicate whether there
was
any change in your internal control over financial reporting that
occurred during the fourth quarter that has materially affected or
is
reasonably likely to materially affect your internal control over
financial reporting, as required by Item 308(c) of Regulation S-K
as
amended effective August 13, 2003.  Please similarly revise future
filings.

d. We note that you refer to Rule 13a-14(c) and 15d-14(c).  Please
note that the definitions of disclosure controls and procedures
are
included in Rule 13a-15(e) and Rule 15d-15(e) of the Exchange Act.
Please revise your 10-K to incorporate these references and
similarly
revise future filings.

Financial Statements - Page F-1

Auditors` Report - Page F-1

2. Please respond to the following comments:
a. Please request Hoberman, Miller, Goldstein & Lesser, to explain
how it is possible to date their report February 11, 2005, wherein
they rely upon an audit conducted by Kost Forer Gabbay & Kasierer
whose audit report is dated March 31, 2005. Please revise or
advise.
b. Please request Kost Forer Gabbay & Kasierer to revise their
report
to refer to the Public Company Accounting Oversight Board (United
States) instead of auditing standards generally accepted in the
United States of America, or tell us why the current reference is
appropriate. Refer to PCAOB Auditing Standard 1.
c. Please request Kost Forer Gabbay & Kasierer to revise their
report
to include an opinion on the results of operations, changes in
shareholders` equity and cash flows for each of the three years in
the period ended December 31, 2004. The current report appears to
only refer to the years ended December 31, 2003 and 2004.
d. Please tell us why the audit report of Kost Forer Gabbay &
Kasierer refers to notes that are not included in your financial
statements.
e. One of the auditor`s reports should clearly state who is taking
responsibility for auditing the conversion of the financial
statements from Israeli GAAP into U.S GAAP.

Note 1. Summary of Significant Accounting Policies - Page F-7

Revenue and Cost Recognition - Page F-9

3. Tell us supplementally and revise future filings to address the
following related to your long-term contracts:
a. We note from page 10 that "from time to time" you design and
manufacture custom systems.  Please tell us why it is appropriate
to
recognize revenue under the percentage of completion method using
a
cost-to-cost basis.  Provide information supplementally including
further details concerning the products and services you provide.
Refer to paragraph 14 of SOP 81-1.
b. Explain whether any of these long-term contracts include
customer
acceptance, installation, training, rights of return, or other
post
shipment obligations.  We note from page 6 that you provide
comprehensive customer support and have upgrades to software
offered
on a regular basis.  Supplementally explain how you recognize
revenue
for these post shipment obligations under EITF 00-21 and SOP 97-2.

*    *    *    *

      As appropriate, please amend your December 31, 2004 10-K and
respond to these comments 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 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
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.
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 comments, 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 in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; 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 filing or in
response to our comments on your filing.
      You may contact Heather Tress, Staff Accountant, at (202)
551-
3624 or me at (202) 551-3604 if you have questions regarding
comments
on the financial statements and related matters.  In this regard,
do
not hesitate to contact Michele Gohlke, Accounting Branch Chief,
at
(202) 551-3327.

        						Sincerely,

							Kate Tillan
							Assistant Chief Accountant
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Mr. Dave Lubbe
Orbit/FR, Inc.
May 19, 2005
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