SecProbe.io

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[Robocom Letterhead]

August 3, 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 July 18, 2005, and respond to each comment as
follows:

      1.    Paragraph 7 of SOP 97-2 states that if an arrangement to deliver
            software or a software system, either alone or together with other
            products or services, requires significant production, modification,
            or customization of software, the entire arrangement should be
            accounted for using contract accounting.

            The basic RIMS software is sold as a standard, off-the-shelf system.
            This system is highly configurable and modifications to the system
            can be made to accommodate customer requirements. These
            modifications are not required to operate the system and are the
            preference of the end user.

            We offer a menu of services that can be requested at the time of the
            original contract, or that may be ordered on a stand-alone basis.
            Our implementation services, such as training, installation and
            consulting, are completed within a short period of time, such as one
            to two weeks. Revenues associated with the sale of these services
            are recognized upon completion of these services.

      2.    We sell third party software and hardware products. The revenues for
            these sales are recorded gross as a principal in accordance with
            each of the factors listed in paragraphs 7 through 17 of EITF 99-19
            based on the following factors:

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Securities and Exchange Commission
June 1, 2005

      7.    We are responsible for providing the product or service to the
            customer.

      8.    We purchase third party products from vendors and take title to such
            products prior to delivery to the end user. We also take title to
            any products returned by customers and have no formal right of
            return policies with our vendors.

      9.    We have complete discretion, within economic constraints, in
            establishing the price charged to our customers.

      10.   We are responsible for installing third party products and
            configuring devices to work in conjunction with our RIMS product.

      11.   We purchase third party products from a variety of different
            suppliers.

      12.   We may perform a facility analysis for the customer to determine the
            amount of third party products required to operate the RIMS system
            at the customer's location. We also include in our standard contract
            the system requirements to run RIMS.

      13.   We take title and assume the risk of loss for third party products.

      14.   We have credit risk for the third party products. Our customers have
            standard 30-day payment terms on all purchases, regardless of our
            terms with suppliers.

      15.   We are the primary obligor in the arrangement, not the supplier.

      16.   The amount we earn from the sale of third party products is not
            fixed.

      17.   We retain all the credit risks of each sale.

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 are 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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