SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 03-09

April 15, 2005

Mr. Brian L. Mower
Chief Accounting Officer
IOMED, Inc.
2441 South 3850 West
Salt Lake City, UT 84120

Re:	IOMED, Inc.
	Form 10-K for the fiscal year ended June 30, 2004
	File No. 1-14059

Dear Mr. Mower:

      We have reviewed your filing and have the following
comments.
We have limited our review of the above referenced filing to only
those issues addressed. Where our comments call for disclosure, we
think you should amend your document in response to these
comments.
Please amend your Form 10-K for the fiscal year ended June 30,
2004
and respond to these comments within 15 business days or tell us
when
you will provide us with a response prior to the expiration of the
15-day period. If you disagree with any comment that calls for
disclosure, please provide a letter prior to your amendment.  You
may
wish to provide us with marked copies of the amendment to expedite
our review.  Your letter should key your responses to our
comments.
Detailed letters greatly facilitate our review.  Please file your
letter on EDGAR under the form type label CORRESP.  Please
understand
that we may have additional comments after reviewing your
amendment
and responses to our 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the fiscal year ended June 30, 2004

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Fiscal Years Ended June 30, 2004 and 2003, pages 22-23
1. Please expand your disclosure to discuss the reason for
material
changes in statement of operations line items.  For example, why
did
research and product development expenses decrease 15% in fiscal
2004?   Please refer to Section III of SEC Release No. FR-72 for
guidance.

Liquidity and Capital Resources, pages 24-25
2. It appears your discussion of material changes in the
components
of cash flows could be improved. Consistent with Section IV of SEC
Release No. FR-72, your discussion should focus on the primary
drivers of and other material factors necessary to an
understanding
of the company`s cash flows and the indicative value of historical
cash flows.  Where there has been material variability in
historical
cash flows, focus on the underlying reasons for the changes, as
well
as on the reasonably likely impact on future cash flows and cash
management decisions.  Include a discussion and analysis of known
trends and uncertainties.

Critical Accounting Estimates, page 25
3. We believe your disclosure related to estimates of items that
reduce gross revenue such as product returns, performance rebates
and
volume pricing rebates could be improved as follows:

a. Disclose the nature and amount of each accrual at the balance
sheet date and the effect that could result from using other
reasonably likely assumptions than what you used to arrive at each
accrual such as a range of reasonably likely amounts or other type
of
sensitivity analysis.
b. Disclose the factors that you consider in estimating each
accrual
such as historical return of products, levels of inventory in the
distribution channel, estimated remaining shelf life, price
changes
from competitors and introductions of generics and/or new
products.
c. To the extent that information you consider in b) is
quantifiable,
disclose both quantitative and qualitative information and discuss
to
what extent information is from external sources, such as end-
customer prescription demand, third-party market research data
comparing wholesaler inventory levels to end-customer demand. For
example, in discussing your estimate of product that may be
returned,
consider disclosing and discussing, preferably by product and in
tabular format, the total amount of product in sales dollars that
could be potentially be returned as of the balance sheet date and
disaggregated by expiration period.
d. If applicable, discuss any shipments made as a result of
incentives and/or in excess of your customer`s ordinary course of
business inventory level.  Discuss your revenue recognition policy
for such shipments.
e. You should consider disclosing a roll forward of the accrual
for
each estimate for each period presented showing the following:
* Beginning balance,
* Current provision related to sales made in current period,
* Current provision related to sales made in prior periods,
* Actual returns or credits in current period related to sales
made
in current period,
* Actual returns or credits in current period related to sales
made
in prior periods, and
* Ending balance.

f. In your discussion of results of operations for the period to
period revenue comparisons, discuss the amount of and reason for
fluctuations for each type of reduction of gross revenue, i.e.
product returns, customer rebates and other discounts and
allowances,
including the effect that changes in your estimates of these items
had on your revenues and operations.

*    *    *    *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 in the filings reviewed by the staff 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 Todd Sherman, staff accountant, at 202-824-
5358
or Don Abbott, senior accountant, at 202-942-2819 if you have
questions regarding the comments. In this regard, do not hesitate
to
contact me, at (202) 942-1803.

								Sincerely,

								Jim B. Rosenberg
								Senior Assistant Chief
Accountant
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Brian L. Mower
IOMED, Inc.
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