SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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									September 7, 2005

Room 4561

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 26, 2005
 		File No. 000-22735

Dear Mr. Balaban:

      We have reviewed your response to our letter dated July 18,
2005 in connection with the above referenced 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 your response to our previous comment no. 1 where you
indicate that the basic RIMS software is sold as a standard, off-
the-
shelf-system.  While we understand that modifications are not
required to operate the system, we do note that, on occasion,
customers request modifications and customizations to the standard
RIMS software.   We note from your previous response letter dated
June 1, 2005, that you consider such modifications or
customizations
to be an integral part of your software and essential to the
functionality of the software.   We are still unclear how you are
accounting for these arrangements. Your footnote disclosures
indicate
that service revenues for project management and modifications are
recorded using the percentage of completion, but it is not clear
if
the software element is also accounted for using contract
accounting.
Pursuant to paragraph 69 of SOP 97-2, if significant modifications
to
the off-the-shelf software are necessary to meet the customer`s
functionality, no element of the arrangement would qualify for
accounting as a service and contract accounting should be applied
to
both the software and service elements of the arrangement.
Please
explain, in detail, how you account for all elements in
arrangements
involving significant modification or customization services.

* * * * *

       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.  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 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.

	You may contact David Edgar at (202)-551-3459 or the
undersigned
at (202) 551-3499 if you have any questions regarding comments on
the
financial statements and related matters.

						Very truly yours,

						Kathleen Collins
						Accounting Branch Chief
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Mr. Irwin Balaban
Robocom Systems International Inc.
September 7, 2005
Page 2

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