SecProbe.io

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Room 4561
August 25, 2005

Mr. James T. Healy
President and Chief Executive Officer
LogicVision, Inc.
25 Metro Drive
Third floor
San Jose, California 95110

      Re:	LogicVision, Inc.
      Form 10-K for the Year Ended December 31, 2004
		Filed March 18, 2005
		Form 10-Q for the Quarter Ended March 31, 2005
		Filed May 16, 2005
		Form 10-Q for the Quarter Ended June 30, 2005
		Filed August 12, 2005
      File No. 0-31773

Dear Mr. Healy,

      We have reviewed the above referenced filing and have the
following comments.  Please note that we have limited our review
to
the matters addressed in the comments below.  We may ask you to
provide us with supplemental 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 comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Item 1. Customers, page 8

1. We note that you disclose the existence of customers that
account
for 10% or more of your consolidated revenues, but you do not
appear
to identify these customers.  Please tell us how you considered
the
requirements of Item 101(c)(1)(vii) of Regulation S-K.

Item 8. Financial Statements

Consolidated Statement of Operations, page 35

2. We note that you amortize developed technology acquired in the
SiVerion business combination to research and development expenses
within your statements of operations.  Please tell us how you
considered Question 17 of the FASB Staff Implementation Guidance
on
Applying SFAS 86.

Notes to Consolidated Financial Statements

Note 2. Summary of Significant Accounting Policies

Revenue Recognition, page 40

3. You disclose on page 24 that your customers` implementation
cycle
is approximately six to twelve months.  Please explain to us the
reasons for these extended implementation cycles and describe your
involvement.  In addition, describe any provisions included in
your
arrangements that protect your customers in the event of an
unsuccessful implementation and indicate how any such provisions
affect your revenue recognition.

4. You disclose in your revenue recognition policy that you
recognize
revenue in accordance with SOP 81-1.  This disclosure, combined
with
the extended implementation cycles, suggest that you may be
recognizing at least a portion of your revenue using contract
accounting.  Please indicate the extent to which you recognize
revenue using contract accounting and describe the related revenue
recognition policies.  In addition, explain to us how you
concluded
that your current revenue recognition policy disclosure adequately
addresses contract accounting.

Item 9A. Controls and Procedures, page 53

5. You disclose here and in your Form 10-Q filings for the
quarters
ended March 31 and June 30, 2005 that an internal control system
"can
provide only reasonable, not absolute, assurance" that the
objectives
of the control system are met.  Please tell us whether your
disclosure controls and procedures are designed to provide
reasonable
assurance of achieving their objectives and whether your chief
executive officer and chief financial officer concluded that your
disclosure controls and procedures are effective at that
reasonable
assurance level.  In addition, explain to us how you complied with
the guidance in Section II.F.4 of SEC Release No. 33-8238.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please submit all correspondence and supplemental materials on
EDGAR
as required by Rule 101 of Regulation S-T.  Please furnish a cover
letter that keys your responses to our comments and provides any
requested information.  Detailed cover letters greatly facilitate
our
review.

      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 filing;

* 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; 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 filing or in
response to our comments on your filing.
      You may contact Stathis Kouninis, Staff Accountant, at (202)
551-3476, Mark Kronforst, Senior Staff Accountant, at (202) 551-
3451
or me at (202) 551-3489 if you have any questions regarding these
comments.

							Very truly yours,

							Brad Skinner
						Branch Chief
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James T. Healy
LogicVision, Inc.
August 25, 2005
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