SecProbe.io

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Mail Stop 4561

				September 7, 2005

Mahendra Negi
Chief Financial Officer
Trend Micro Incorporated
Shinjuku MAYNDS Tower, 1-1
Yoyogi 2-chome
Shibuya-ku, Tokyo 151-0053, Japan

Re:	Trend Micro Incorporated
Form 20-F for Fiscal Year Ended December 31, 2004
File No. 333-10486

Dear Mr. Negi:

      We have reviewed the above referenced filings and have the
following comments.  Please note that 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 document. We
may ask you to provide us with supplemental information so we may
better understand your disclosure.  Please be as detailed as
necessary in your explanation.  After reviewing this information,
we
may 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
filings.
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 for the Fiscal Year Ended December 31, 2004

Information on the Company

Business Overview

Regional Overview, page 26

1. We note your disclosure that you "make rebate payments to
SOFTBANK
based on SOFTBANK`s achievement of sales targets."  Tell us the
amount of rebates recorded in each period presented, where the
rebates are reflected in the consolidated statements of income and
your accounting policy related to these rebate payments.  Describe
your consideration of paragraph 9 of EITF 01-09.

Note 1 - Significant Accounting Policies

Revenue recognition, page F-12

2. You state that the Company may approve certain returns from
intermediaries or end-users.  Tell us how your accounting for
these
return rights complies with each of the criteria set forth in
paragraph 6 of SFAS 48.  In addition, your response should address
SAB Topic 13A(4)(b).

3. Your disclosures on page 33 indicate that you maintain separate
valuation accounts for the allowances for doubtful accounts and
sales
returns.  Tell us why you have not separately presented these
amounts
in Schedule II.  Provide us with this data separately for each
valuation allowance.

Note 10 - Research and development and maintenance sots, and
software
development costs, page F-20

4. We note that you classify maintenance costs within operating
expenses.  Tell us why you do not consider these costs to be costs
of
revenue.  Describe the nature of the maintenance costs, indicating
whether they are incurred for enhancement or for maintenance.
Address Questions 23 to 25 of FASB Staff Implementation Guide to
SFAS
86 in your response.  Additionally, provide a similar explanation
for
the classification of customer support costs (Note 18, page F-33)
as
operating expenses instead of costs of revenue.  Describe whether
the
support is for sales and marketing or for post-sales customer
support.

Note 12 - Short-term borrowings and log-term debt, page F-22

5. We note that "based on [your] incentive plans, the parent
company
issued unsecured bonds with detachable warrants and bought all of
the
warrants at the same time for the purpose of distributing such
instruments to the directors and certain employees of the parent
company and its subsidiaries as a part of their remuneration."
With
regard to these transactions, we have the following comments:
* Given that you repurchased these warrants "at the same time" as
they were issued, explain why you structured these transactions as
debt issuances rather than issuing the warrants to the individuals
directly.
* Tell us how you accounted for the relative fair value of the
warrants at issuance and upon repurchase.

Note 13 - Stock Option, page F-22

6. We note that the warrant activity table shows warrants being
redeemed.  Tell us what is meant by "redemption" of these
warrants,
the circumstances surrounding these redemptions and at what value
were they redeemed (e.g., fair value). See Issue 23 of EITF 00-23
and
Question 14 of FIN 44.

       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.  You may wish to provide us with
marked
copies of any amendment to expedite our review.  Please furnish a
cover letter with any 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 any amendment and your
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 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 Jason Niethamer at 202-551-3855, Tammy Tangen
at
202-551-3443 or me at 202-551-3730 if you have questions regarding
the above comments.

Sincerely,

Stephen Krikorian Accounting Branch Chief

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Mahendra Negi
Trend Micro Incorporated
September 7, 2005
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