SecProbe.io

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Mail Stop 6010

August 5, 2005

Ze`ev Kirshenboim, Chief Executive Officer and Chief Financial
Officer
ACS-Tech 80 Ltd
Post Office Box 5668
Migdal Ha`emek, Israel  10500

Via U S Mail and FAX [011-972-4-654-6443 ]

	Re:	ACS-Tech 80 Ltd.
		Form 20-F for the fiscal year ended December 31, 2004
		Forms 6-K for 2005
		File No.  1-14662

Dear Mr. Kirshenboim:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures, and do not intend to expand our review to
other
portions of your documents. Where indicated, we think you should
revise your documents in response to these comments in all future
filings with the Commission.  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 some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  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 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.

Mr. Ze`ev Kirshenboim
ACS-Tech 80 Ltd
August 4, 2005
Page 2

Form 20-F for fiscal year ended December 31, 2004

Operating and Financial Review and Prospects, page 22

Operating Results, page 26

1. We see the 56% increase in revenues in 2004. In future filings
please provide more detailed and specific discussion of reasons
for
the significant increase.  For instance, please more specifically
describe how the improved business environment impacted revenues.
Also provide some description of new products introduced and their
impact on revenues.

2. We read in Note 15 that you have several operating segments.
To
the extent important to an understanding of your operating
results,
please expand future filings to discuss and to compare the
revenues
generated by each segment, and the operating income produced by
each
segment.

Financial Statements

Note 2-K  Revenue Recognition, page F-12

3. We see that the revenue policies make disclosure about the
generic
criteria from SAB 104 for revenue recognition.  Please expand
future
filings to clarify how you apply those criteria in your specific
circumstances.  For instance, disclose what you consider to be
"pervasive evidence of an agreement" and make disclosure about the
factors you consider in concluding that "collectibility is
probable."
Also clarify shipping terms and identify when you consider
delivery
to have occurred.  Your response should show us how you intend to
apply this comment.

4. We see that you consider whether "significant obligations"
exist
in assessing the timing of revenue.  Please expand future filings
to
make disclosure about the nature and extent of post shipment
obligations and customer acceptance protocols, including more
specific detail about how these matters are considered in the
timing
of revenues.   Your response should show us how you intend to
apply
this comment.

5. Tell us more about the terms and conditions of sales to
distributors.  Show us that your revenue practices for
transactions
with these entities are appropriate.

Mr. Ze`ev Kirshenboim
ACS-Tech 80 Ltd
August 4, 2005
Page 3

Note 2-T  Impairment of Property and Equipment, page F-14

6. Your accounting policy for impairment of property and equipment
does not appear to conform to US GAAP.  In future filings please
expand Note 16 to provide disclosure about this potential
Israeli/US
GAAP difference.

Note 10(C)  Shareholders` Equity, page F-24

7. We see that certain options were canceled and re-granted in
December 2003.  For US GAAP purposes, tell us how your accounting
considers the guidance from FIN 44.

Report of Independent Registered Public Accounting Firm, page T-1

8. In future filings please revise the second paragraph of the
audit
report to refer to the PCAOB by its full name. That is, the Public
Company Accounting Oversight Board (United States).

9. In future filings please disclose the city and state where the
report was signed.  Refer to Rule 2-02 of Regulation S-X.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a response letter that keys your responses to our
comments and provides the requested information.  Confirm that you
will comply with these comments in all future filings with the
Commission.  Detailed response letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your responses to our comments and the requested
information.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that the filing includes all information required under
the
Securities Exchange Act of 1934 and 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.

Mr. Ze`ev Kirshenboim
ACS-Tech 80 Ltd
August 4, 2005
Page 4

	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 filing;

* staff comments or changes to disclosure in response to staff
comments 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 Jeanne Bennett at (202) 551-3606, or me at
(202) 551-3605, if you have questions regarding our comments.  In
our
absence you may contact Brian R. Cascio, Accounting Branch Chief,
at
(202) 551-3676.

      Sincerely,

      Gary R. Todd
								Reviewing Accountant
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