SecProbe.io

November 5, 2013

Via E-mail
Mr. Eric Soyer
Chief Financial  Officer
EDAP TMS S.A.
Parc d’Activites la Poudrette -Lamartine
4/6, rue du Dauphiné
69120 Vaulx -en-Velin, France

 Re: EDAP TMS S .A.
  Form 20-F for the Fiscal Year Ended December 31, 2012
  Filed April 2, 2013
File No. 000-29374

Dear Mr. Soyer :

We have reviewed your filing s and have the following comment s. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your fact s and circumstances  please tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have  additional comments.

Form 20 -F for the Fiscal Year Ended December 31, 2012

Note 1 -4 Revenue Recognition, page F -9

1. We see from your disclosure in Note 1 -4 that you provide training upon installation.
Please tell us about the installation and training, whether these are performed after
shipment of your products and how each of these impact the timing of your revenue
recognition.

Mr. Eric Soyer
EDAP TMS S.A.
November 5, 2013
Page 2

Note 23 – Fair Value of Financial Instruments, page F -41

2. Please revise future filings to provide all of the disclosures required by FASB ASC 825 -
10-50-10, including the level of the fair value hierarchy within which the fair value
measurements are categorized in their entirety.

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 the information the Securities Exchange Act of
1934 and all appli cable Exchange Act rules 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 responding to our comments, please provide  a written 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 forec lose
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.

You may  contact Julie Sherman  at (202) 551 -3640, or me at (202) 5 51-3676 , if
you have any questions regarding these comments.  In this regar d, do not hesitate to
contact Martin James, Senior Assistant Chief Accountant, at (202) 551 -3671 .

       Sincerely,

        /s/ Brian Cascio

       Brian Cascio
       Accounting Branch Chief