SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

									May 24, 2005

Fax (516) 795-6933
Mail Stop 0406

Irwin Balaban
Chief Executive Officer
Robocom Systems International Inc.
511 Ocean Avenue
Massapequa, NY 11758

      RE: 	Robocom Systems International Inc
 		Form 10-KSB
		Filed on August 23, 2004
 		File No. 000-22735

Dear Mr. Balaban:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  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
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 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 fiscal year ended May 31, 2005

Note 1. Organization and Significant Accounting Policies

Revenue Recognition, page 25

1. We note that service revenues for project management and
modifications are recorded using the percentage of completion
method.
Supplementally explain how you considered the factors cited in
paragraph 70 and 71 of SOP 97-2 in accounting for such services.
Tell us if you are accounting for the entire contract, including
the
software license, using contract accounting and tell us how you
considered paragraph 74 of SOP 97-2 in your accounting for such
contracts.

2. Tell us about the payment terms you offer.  Address how you
determine the payment terms you offer your customers and what you
believe your "normal and customary" payment terms are.  Note that
extended payment terms may include periods less than one year,
particularly if the use of the extended payment terms is not your
customary practice.  Refer to paragraphs 27 through 30 of SOP 97-
2.

3. We note the Company sells third party hardware and software
products.  Supplementally tell us how you considered each of the
factors of EITF 99-19 in determining whether to account for such
sales on a gross or net basis.

4. Tell us whether your product sales have any contingencies such
as
rights of return, conditions of acceptance, warranties, etc., and
tell us  the nature of these contingencies and your accounting
treatment for each.  Describe significant assumptions, material
changes and reasonably likely uncertainties.

5. We note your disclosure on page 7 that the Company markets its
products through resellers in Argentina, the UK and Indonesia.
Supplementally explain how you recognize revenue for products sold
through indirect channels.  Also, tell us whether you offer your
resellers a right of return or any other consideration (i.e. price
concessions, rebates, cooperative advertising, etc.) and tell us
your
accounting treatment for each.

* * * * *

       As appropriate, please amend your filing 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 understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	 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 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 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 David Edgar at (202)-551-3459 or Kathleen
Collins at (202) 551-3499, or the undersigned at (202) 551-3730 if
you have any questions regarding comments on the financial
statements
and related matters.

						Very truly yours,

						Craig D. Wilson
						Senior Assistant Chief Accountant

??

??

??

??

Robocom Systems International Inc.
May 24, 2005

</TEXT>
</DOCUMENT>