SecProbe.io

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[Robocom Letterhead]

June 1, 2005

Mr. Craig D. Wilson
US Securities and Exchange Commission
Washington, D.C. 20549

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

Dear Mr. Wilson,

We have reviewed your comments on our Form 10-KSB for the year ended May 31,
2004, in your letter dated May 24, 2005, and respond to each comment as follows:

      1.    We recognize revenues for project management and modification
            services on a percentage of completion basis. We consider these
            services to be an integral part of our software and essential to the
            functionality of the software in accordance with the terms of
            paragraph 70, 71 and 74 of SOP 97-2 as follows:

            a.    Our project management and software modification services are
                  not available from other vendors and are unique to us.

            b.    We are an experienced provider of these services.

            c.    Software modifications may include significant alterations to
                  the features and functionality of RIMS, our standard software,
                  and complex interfaces may be necessary for our software to
                  operate in the customer's environment.

            d.    Milestones and acceptance criteria may be requested by the
                  customer and affect the recognition of software license fees.

            However, other implementation services, such as training,
            installation and consulting are recognized upon completion. These
            services may be requested by customers in the initial contract or
            may be ordered on an individual basis as needed.

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      2.    We offer standard 30-day terms to most of our customers on all
            purchases. For two customers, payment terms are extended to as long
            as 60 days. Upon the signing of a contract or receipt of a purchase
            order from a customer, fees for licensing, services and/or hardware
            are fixed and determinable. We do not offer any installment payment
            plans and are not in the business of financing our software or
            services. As a result, we believe we are in compliance with
            paragraph 27-30 of SOP 97-2, in that the payments are fixed and
            determinable and have a short payment period. Furthermore,
            recognition of revenues is based upon delivery of the product and/or
            completion of the service and unrelated to the timing of the receipt
            of payment from the customer.

      3.    We sell third party software and hardware products. The revenues for
            these sales are recorded gross as a principal in accordance with
            EITF 99-19 based on the following factors:

            a.    We act as the principal in the transaction, contracting with
                  the customer to deliver the third party product. We enter into
                  reseller agreements with third party vendors that authorize us
                  to sell third party products and provide a discounted purchase
                  price.

            b.    We purchase third party products from vendors and take title
                  to such products prior to delivery to the end user.

            c.    We assume the risk of loss for third party products, as well
                  as the rewards of such ownership.

      4.    Our standard contract for RIMS includes a warranty provision as
            follows.

      SECTION 4. WARRANTY

            4.1   We warrant that, if the Basic Software is installed by you on
                  the System as provided in the Software Documentation and the
                  user manuals and other documentation provided by the
                  manufacturer, licensor, or distributor of the Equipment and
                  the Third-Party Software (the "Third-Party Documentation")
                  (Software Documentation and Third-Party Documentation,
                  collectively referred to as "Documentation") then for a period
                  of twelve (12) months from the date the Licensed Property is
                  delivered to you ("Warranty Period"), the Basic Software shall
                  be free from any defect in workmanship or materials which
                  prevents it from performing or operating substantially in
                  accordance with the specifications in the Software
                  Documentation. If we receive written notice from you of such a
                  defect arising in the Basic Software within the Warranty
                  Period and if the Basic Software has not been modified,
                  changed or altered by you in any manner, then at no charge to
                  you, we will correct or repair the defect or replace the
                  defective component of the Basic Software as promptly as
                  practicable. Our liability, and your sole remedy, for breach
                  of the foregoing warranty shall be limited to the correction
                  of defects or replacement of the Basic Software. After the

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                  Warranty Period, all correction, repairs and replacement will
                  only be made under a separate Support and Maintenance
                  Agreement.

            4.2   Any changes, additions or modifications to the Basic Software
                  not made by us or with our specific written authorization
                  shall void the warranty and we will have no further obligation
                  to correct, repair and/or replace the Basic Software as
                  provided hereunder.

            4.3   If any defect identified in a written notice to us from you
                  during the Warranty Period proves not to be a defect covered
                  by the warranty contained in Section 4.2, all expenses,
                  including hourly service rates, incurred by us in response to
                  your written notice, shall be paid by you no later than
                  fifteen (15) days after delivery of an invoice for those
                  expenses.

            4.4   EXCEPT AS SPECIFICALLY PROVIDED IN SECTION 4.1, THERE ARE NO
                  WARRANTIES, EXPRESS OR IMPLIED, MADE BY US IN CONNECTION WITH
                  THIS AGREEMENT OR THE LICENSED PRODUCT, INCLUDING, BUT NOT
                  LIMITED TO, ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS
                  FOR A PARTICULAR PURPOSE.

            a.    Historically, we have not experienced any significant costs
                  associated with our warranty and therefore, we do not disclose
                  or account for contingencies for our warranty.

            b.    In certain instances, the customer can request conditions of
                  acceptance. In these cases, we do not recognize the full
                  license fee as revenue until all the conditions of acceptance
                  have been met.

            c.    Other than as stated above, our product sales do not have any
                  other rights of return, conditions of acceptance, or
                  warranties.

            d.    There are no significant assumptions, material changes or
                  reasonably likely uncertainties associated with our product
                  sales.

      5.    We currently have two active distributors, one of which is located
            in Argentina and the other is located in Indonesia. Our former UK
            distributor is no longer selling the RIMS product. Each of these
            distributors is required to sign an international distributor
            agreement with us. We then receive revenue from the sale of
            licensing and maintenance from these distributors. All costs of
            selling and implementing the software by a distributor are borne by
            that distributor. We will provide second-line support to the
            distributor with respect to standard services and maintenance. We
            warrant the software to distributors in the same manner as stated in
            the explanation for number 4. We do not account for contingencies of
            warranty based on immaterial historical expenses.

            a.    For our Argentina distributor, licensing revenues are
                  recognized at 50% of the distributor's contracted sales price
                  with the end user. For our

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                  Indonesia distributor, our net license fee is negotiated based
                  on the number of concurrent users and modules specified. In
                  both cases, we receive a copy of the contract as evidence of
                  the sale and then forward the software to the distributor for
                  release to the customer. Revenue is recognized at this time.

            b.    Maintenance revenues are recognized at 50% of the distributors
                  contracted sales price with the end user. We recognize a
                  portion of the annual maintenance contract ratably over twelve
                  months.

            c.    We do not offer our resellers any rights of return, price
                  concessions, rebates or cooperative advertising.

Based on our review of your comments, we believe our accounting policies are in
compliance with GAAP and we are not required to amend our Form 10-KSB for the
year ended May 31, 2004.

We acknowledge that we is responsible for the adequacy and accuracy of our
disclosures and that 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. We acknowledge that we may not assert staff comments as a
defense in any proceeding initiated by the Commission or any person under
federal securities laws of the United States.

If you have any comments or concerns about our responses, you may contact the
undersigned at (516) 795-5100, extension 221 or Kathleen Poulos at (516)
795-5100, extension 287.

Thank you,

/s/ Irwin Balaban
-----------------
Irwin Balaban
President and
Chief Executive Officer

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