SecProbe.io

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Mail Stop 0407

      							May 26, 2005

Mr. Gerry Racicot
President and Chief Executive Officer
Eiger Technology, Inc.
330 Bay Street, Suite 602
Toronto, Ontario M5H 2S8

	Re:	Eiger Technology, Inc.
      Form 20-F/A for Fiscal Year Ended September 30, 2004
		Filed May 3, 2005
		File No. 0-29320

Dear Mr. Racicot:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise your documents 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 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 20-F/A for Fiscal Year Ended September 30, 2004

Item 5.  Operating and Financial Review and Prospects, page 14

A.  Operating Results, page 14

1. Expand your discussion of the changes in each income statement
caption to provide a more comprehensive analysis of the reason for
each significant change.

2. We note your disclosure at page 15 that you recorded non-
recurring
items relating to the write-down of certain capital assets,
inventory
and goodwill.  Disclose the nature and amounts of each of these
charges.  In addition, we note that you have recorded a charge for
the decline in value of long-term investments of $1,21,000.
Disclose
the nature of these investments and how you determined that the
investments were impaired as of September 30, 2003.

B.  Liquidity and capital resources, page 16

3. Expand your discussion of liquidity and capital resources to
include a discussion of your internal and external sources of
liquidity, a discussion of your sources and amounts of cash flows
and
a discussion of your level of borrowings and the effect of these
borrowings on your liquidity.  In addition, provide a tabular
presentation of contractual obligations, as described in Item 5.F.
of
Form 20-F.

Item 15.  Controls and Procedures, page 33

4. We note your disclosure that your "Chief Executive Officer and
Chief Financial Officer, after evaluating the effectiveness of the
Company`s disclosure controls and procedures (as defined in US
Exchange Act Rule 13a-14(c)) within 90 days of the date of this
Form
20-F, have concluded that, as of such date, the Company`s
disclosure
controls and procedures were effective to ensure that material
information relating to the Company was made known to them by
others
within the Company particularly during the period in which this
Form
20-F was being prepared"  (emphasis added).  Please note that
filings
after August 14, 2003 must comply with the disclosure requirements
of
revised Item 307.   That is, you must disclose the conclusion of
your
certifying officers regarding the effectiveness of your disclosure
controls and procedures as of the end of the period covered by the
report, based upon the evaluation of these controls and
procedures.
Please amend your Form 20-F accordingly.

5. We note your disclosure that your principal executive officer
and
principal financial officer have concluded that your disclosure
controls and procedures are "effective to ensure that material
information relating to the Company was made known to them by
others
within the Company particularly during the period in which this
Form
20-F was being prepared."    Please revise to indicate, if true,
that
your disclosure controls and procedures are effective in ensuring
that information required to be disclosed in the reports that you
file or submit under the Exchange Act is recorded, processed,
summarized and reported, within the time periods specified in the
Commission`s rules and forms and are effective in ensuring that
information required to be disclosed in the reports that you file
or
submit under the Exchange Act is accumulated and communicated to
your
management, including your principal executive and principal
financial officers, to allow timely decisions regarding required
disclosure.  See Rule 13a-15(e) of the Exchange Act.
Alternatively,
you may simply state that your disclosure controls and procedures
are
effective.

6. We note your disclosure that there were "no significant changes
in
the Company`s internal controls or in other factors that could
significantly affect these controls subsequent to the date our
Chief
Executive Officer and our Chief Financial Officer completed their
evaluation, nor were there any significant deficiencies or
material
weaknesses in the Company`s internal controls requiring corrective
actions" (emphasis added).  Item 308(c) of Regulation S-K requires
the disclosure of any change in your internal control over
financial
reporting identified in connection with an evaluation thereof that
occurred during your last fiscal quarter (or your fourth fiscal
quarter in the case of an annual report) that has materially
affected, or is reasonably likely to materially affect, your
internal
control over financial reporting.  Please revise to provide the
disclosure required by Item 308(c) of Regulation S-K.

Consolidated Financial Statements

7. Revise to include an audited statement of operations and a
statement of cash flows for the year ended September 30, 2002, as
required by Item 8 of Form 20-F.  In addition, revise your
disclosure
at Note 12 to present the changes in the balance of shareholders`
equity for the year ended September 30, 2002.

Auditors` Report, page 1

8. It appears that you have only included an auditors` report that
covers the year ended September 30, 2004.  The report indicates
that
the financial statements for the year ended September 30, 2003
were
audited by another public accounting firm whose report is
attached.
Please revise to include audit reports that cover all periods
presented in the Form 20-F.

9. Auditing Standard No. 1 (AS 1) requires that auditors` reports
state compliance with "the standards of the Public Company
Accounting
Oversight Board (United States)."  Ask your auditors to revise
their
report to comply with AS 1.

*    *    *    *

      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.  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 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 to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Melissa Hauber, Senior Staff Accountant, at
(202) 551-3368 or Robert Littlepage, Accountant Branch Chief, at
(202) 551-3361 if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
551-3810 with any other questions.

								Sincerely,

								Larry Spirgel
								Assistant Director

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Mr. Gerry Racicot
Eiger Technology, Inc.
May 26, 2005
Page 5

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