SecProbe.io

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                                                       ERIC M. HELLIGE

                                                       DIRECT TEL: 212-326-0846
                                                       DIRECT FAX: 212-798-6380
                                                       ehellige@pryorcashman.com

                                       September 13, 2005

VIA FACSIMILE - (202) 942-9542

Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549

Attention: Ms. Maryse Mills-Apenteng

            Re:   Robocom Systems International, Inc.
                  Preliminary Schedule 14A
                  Filed on August 26, 2005
                  Form 10-KSB for the years ended May 31, 2004 and 2005
                  File No. 0-22735

Dear Ms. Mills-Apenteng:

      Thank you for taking the time last week to answer our questions regarding
the Staff's letter dated September 7, 2005 relating to the above-referenced
preliminary proxy statement on Schedule 14A (the "Proxy Statement"). Our client,
Robocom Systems International, Inc. (the "Company"), intends to file with the
Securities and Exchange Commission (the "Commission") Amendment No. 1
("Amendment No. 1") to the Proxy Statement on Schedule 14A containing its
responses to the Staff's comment letter. In an effort to focus our responses in
Amendment No. 1, we have set forth below our proposed responses to the
Commission's comments along with a copy of Amendment No. 1 which is marked to
show the proposed changes to the Proxy Statement. The numbered responses below
correspond to the numbered paragraphs of the Staff's letter. Capitalized terms
not otherwise defined in this letter have the meanings ascribed to them in the
Proxy Statement.

                                    Responses

1.    We understand that the responses set forth the Company's letter dated
      September 9, 2005 to Kathleen Collins of the Commission were acceptable to
      the Commission.

2.    The Company acknowledges the Staff's comment and has revised the Proxy
      Statement to include as Annex C the unaudited, pro forma balance sheet and
      statement of operations

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Securities and Exchange Commission
September 13, 2005
Page 2

      for its fiscal year ended May 31, 2005 which gives effect to the asset
      sale as if it was consummated on June 1, 2004 (the beginning date of the
      period covered by the pro forma financial statements).

3.    The Company confirms that Avantce RSI, LLC is not an affiliate of the
      Company. Amendment No. 1 contains the appropriate disclosure in "Questions
      and Answers about the Special Meeting", the "Summary Term Sheet" and the
      section titled "Information about the Buyer" under Proposal No. 1.

4.    The requested Summary Term Sheet and pro forma financial information have
      been added to Amendment No. 1 in response to this comment. With regard to
      the Staff's request to provide historical information regarding the
      business being sold, the Company notes that it is selling all of its
      business and believes that the incorporation by reference of its Annual
      Report on Form 10-KSB for the fiscal year ended May 31, 2005 satisfies
      this requirement.

5.    Additional disclosure has been added to the section titled "Background of
      the Asset Sale" under Proposal No. 1 in response to this comment.

6.    Additional disclosure has been added to "Questions and Answers about the
      Special Meeting", the "Summary Term Sheet" and the section titled "Use of
      Proceeds of the Asset Sale" under Proposal No. 1 to clarify that no
      dividend has been declared in connection with the asset sale and that
      there can be no assurance that the Company's board of directors will
      declare a dividend in the future.

7.    Additional disclosure has been added to "Questions and Answers about the
      Special Meeting", the "Summary Term Sheet" and the section titled
      "Business of the Company Following the Asset Sale" under Proposal No. 1 to
      indicate that the Company has no current commitments or agreements to
      pursue any particular transaction or strategy following the consummation
      of the asset sale.

8.    Additional disclosure has been added to "Questions and Answers about the
      Special Meeting", the "Summary Term Sheet" and the section titled
      "Purchase Price" under Proposal No. 1 to clarify that there are no other
      purchase price adjustments and that the Company anticipates that it will
      have working capital on the closing date in excess of the target amount,
      although there can be no assurance of any such excess.

9.    The disclosure in the section titled "Treatment of Outstanding Options"
      under Proposal No. 1 has been revised to indicate that outstanding options
      to purchase the Company's common stock will remain outstanding on the same
      terms following the consummation of the asset sale.

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Securities and Exchange Commission
September 13, 2005
Page 3

10.   The Company acknowledges the Staff's comment. The Company understands that
      no specific change to the Proxy Statement is required as a result of this
      comment.

      The Company acknowledges that (i) it is responsible for the adequacy and
accuracy of the disclosure in its filings; (ii) Staff comments or changes to
disclosure in response to Staff comments do not foreclose the Commission from
taking any action with respect to the Company's filings; and (iii) the Company
may not assert any Staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United
States.

      The Company believes it has fully responded to the comments of the
Commission. We hereby respectfully request that the Staff review our proposed
responses on an expedited basis. If the Commission has any questions or further
comments, the Company respectfully requests that such comments be directed to
the undersigned as soon as practicable as the Company would like to file
Amendment No. 1 by the close of business on Wednesday, September 14, 2005, and
begin mailing it definitive proxy statement to shareholders not later than
Friday, September 16, 2005.

                                        Very truly yours,

                                        /s/ Eric M. Hellige

                                        Eric M. Hellige

cc:   Mr. Irwin Balaban, Chief Executive Officer
      Eisner & Lubin LLP

<PAGE>

   As filed with the Securities and Exchange Commission on September 13, 2005

                                  UNITED STATES
                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                  SCHEDULE 14A
                                 (Rule 14a-101)
                     INFORMATION REQUIRED IN PROXY STATEMENT

                            SCHEDULE 14A INFORMATION

                    Proxy Statement Pursuant to Section 14(a)
                     of the Securities Exchange Act of 1934

                                 AMENDMENT NO. 1

                                   ----------

Filed by the Registrant |X|

Filed by a Party other than the Registrant |_|

Check the appropriate box:

|X|   Preliminary Proxy Statement

|_|   Confidential, for the use of the Commission only (as permitted by Rule
      14a-6(e)(2))

|_|   Definitive Proxy Statement

|_|   Definitive Additional Materials

|_|   Soliciting Material Pursuant to ss.240.14a-12

                                   ----------

                       ROBOCOM SYSTEMS INTERNATIONAL INC.
                (Name of Registrant as Specified in Its Charter)

      (Name(s) of Person Filing Proxy Statement, if Other than Registrant)

                                   ----------

Payment of Filing Fee (Check the appropriate box):

|X|   No fee required

|_|   Fee computed on table below per Exchange Act Rules 14a-6(i)(1) and 0-11.

      (1)   Title of each class of securities to which transaction applies:

      (2)   Aggregate number of securities to which transaction applies:

      (3)   Per unit price or other underlying value of transaction computed
            pursuant to Exchange Act Rule 0-11 (set forth the amount on which
            the filing fee is calculated and state how it was determined):

      (4)   Proposed maximum aggregate value of transaction:

      (5)   Total fee paid:

|_|   Fee paid previously with preliminary materials:

|_|   Check box if any part of the fee is offset as provided by Exchange Act
      Rule 0-1l(a)(2) and identify the filing for which the offsetting fee was
      paid previously. Identify the previous filing by registration statement
      number, or the Form or Schedule and the date of its filing.

      (1)   Amount Previously Paid:

      (2)   Form, Schedule or Registration Statement No.:

      (3)   Filing Party:

      (4)   Date Filed:

<PAGE>

                       ROBOCOM SYSTEMS INTERNATIONAL INC.

                          NOTICE OF SPECIAL MEETING OF
                   SHAREHOLDERS TO BE HELD ON OCTOBER 11, 2005

                                        September __, 2005

To Our Shareholders:

      Notice is hereby given that a special meeting of shareholders of Robocom
Systems International Inc., a New York corporation (referred to herein as "we"
or "us"), will be held in the Executive Conference Room of our corporate offices
located at 511 Ocean Avenue, Massapequa, New York 11758, on October 11, 2005, at
10:00 a.m., local time, for the following purposes:

      1.    To approve the proposed sale of substantially all of our assets to
            Avantce RSI, LLC pursuant to the asset purchase agreement annexed to
            the accompanying proxy statement.

      2.    To transact such other business as may properly come before the
            special meeting and any adjournments thereof.

      The foregoing items of business are more fully described in the proxy
statement accompanying this notice.

      Our board of directors has fixed August 19, 2005 as the record date for
the determination of our shareholders entitled to notice of, and to vote at, the
special meeting. A list of such shareholders will be available for examination
by a shareholder for any purpose germane to the special meeting during ordinary
business hours at our corporate office located at 511 Ocean Avenue, Massapequa,
New York 11758, during the ten (10) business days prior to the special meeting
and during the special meeting.

      Whether or not you plan to attend the special meeting, you should
complete, sign, date and promptly return the enclosed proxy card, to ensure that
your shares will be represented at the meeting. If you attend the special
meeting and wish to vote in person, you may withdraw your proxy and vote in
person. You should not send any certificates representing stock with your proxy
card.

                                        For the Board of Directors

                                        Irwin Balaban
                                        Chairman of the Board
                                        and Chief Executive Officer

<PAGE>

                                TABLE OF CONTENTS

QUESTIONS AND ANSWERS ABOUT THE SPECIAL MEETING ...........................    i

SUMMARY TERM SHEET ........................................................    v

INFORMATION CONCERNING SOLICITATION AND VOTING ............................    1

   Record Date and Voting Securities ......................................    1
   Revocability of Proxies ................................................    1
   Voting and Solicitation ................................................    1
   Quorum; Abstentions; Broker Non-Votes ..................................    2

SPECIAL NOTE REGARDING FORWARD-LOOKING STATEMENTS .........................    2

PROPOSAL NO. 1 TO APPROVE THE PROPOSED ASSET SALE .........................    3

   General ................................................................    3
   Background of the Asset Sale ...........................................    3
   Information about the Buyer ............................................    4
   Our Reasons for the Asset Sale .........................................    5
   Summary of the Terms of the Asset Purchase Agreement ...................    6
   Assets to be Sold ......................................................    6
   Obligations to be Assumed by Avantaee ..................................    7
   Purchase Price .........................................................    7
   Indemnification ........................................................    8
   Termination ............................................................    8
   Other Terms ............................................................    8
   Interests of our Directors and Executive Officers ......................    9
   Regulatory Approvals ...................................................    9
   Use of Proceeds from the Proposed Asset Sale ...........................   10
   Business of the Company Following the Asset Sale .......................   11
   Material United States Federal Income Tax Consequences .................   11
   Treatment of Outstanding Stock Options .................................   12
   Appraisal Rights .......................................................   12
   Vote Required and Board Recommendation .................................   14

SHAREHOLDER PROPOSALS .....................................................   14

SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT ............   15

OTHER MATTERS .............................................................   15

EXPERTS ...................................................................   16

ANNUAL REPORT .............................................................   16

PRO FORMA FINANCIAL STATEMENTS ............................................   16

INCORPORATION OF DOCUMENTS BY REFERENCE ...................................   16

WHERE YOU CAN FIND MORE INFORMATION .......................................   16

<PAGE>

                                TABLE OF CONTENTS
                                   (continued)

ANNEX A - Asset Purchase Agreement

ANNEX B - Copy of Section 623 and 910 of the New York Business Corporation Law
          regarding Appraisal Rights

ANNEX C - Pro Forma Financial Statements

                                       ii
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                 QUESTIONS AND ANSWERS ABOUT THE SPECIAL MEETING

Q:    What proposal will be voted on at the special meeting?

A:    The proposal to be voted on at the special meeting is whether to approve
      the sale of substantially all of our assets to Avantce RSI, LLC, a
      Delaware limited liability company ("Avantce"). The assets that we propose
      to sell to Avantce primarily consist of our RIMS software product, all of
      our intellectual property rights, contracts, accounts receivables and
      tangible personal property and certain cash, all pursuant to the terms of
      the Asset Purchase Agreement attached to the accompanying proxy statement
      as Annex A. The proposed sale of assets is referred to as the "asset
      sale". The assets to be sold in the asset sale are substantially all of
      the assets of our company.

Q:    Who is the purchaser?

A:    The purchaser of our assets will be Avantce RSI, LLC, a Delaware limited
      liability company. Avantce is a private investment company focused on
      investments in mature segments of the information technology industry. Its
      principal place of business is 508 Ashley Way, Peachtree City, Georgia.
      Avantce is not an affiliate of our company. For more information regarding
      Avantce, you may visit Avantce's websit