SecProbe.io

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                                                       ERIC M. HELLIGE

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

                                                September 15, 2005

VIA EDGAR

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

Ladies and Gentlemen:

      On behalf of Robocom Systems International, Inc., a corporation organized
pursuant to the laws of the State of New York (the "Company"), and in connection
with the special meeting of shareholders of the Company, we hereby file by EDGAR
transmission a copy of Amendment No. 1 ("Amendment No. 1") to the Company's
preliminary proxy statement on Schedule 14A (the "Proxy Statement").

      This letter sets forth our responses to the Staff's letter dated September
7, 2005 relating 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 Amendment
No. 1.

                                    Responses

1.    The Company responded to this comment in its letter to the Staff dated
      September 9, 2005 which was transmitted via EDGAR.. In the Staff's letter
      dated September 12, 2005, the Staff indicated that it had completed its
      review of the Company's Annual Report on Form 10-KSB and related filings
      and had no further comments at this time.

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Securities and Exchange Commission
September 15, 2005
Page 2

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 for its fiscal year ended May 31, 2005. The
      unaudited pro forma condensed balance sheet of the Company at May 31, 2005
      gives effect to the proposed sale as if it had occurred on May 31, 2005.
      The unaudited pro forma condensed statement of operations for the fiscal
      year ended May 31, 2005 gives effect to the proposed sale as if it had
      occurred as of June 1, 2004.

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 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 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.

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Securities and Exchange Commission
September 15, 2005
Page 3

      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.

      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.

                                                Very truly yours,

                                                /s/ Eric M. Hellige

                                                Eric M. Hellige

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