SecProbe.io

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Mail Stop 4561

				December 29, 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 your response letter dated October 7, 2005
along with the above referenced filing and have the following
additional 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

Prior Comment Number 1

1. We have reviewed your response to our prior comment and note
the
increasing significance of rebate payments.  Expand your
accounting
policy disclosures in future filings to clearly describe your
accounting for significant rebate arrangements.  If material,
quantify rebates recorded in each period presented.

2. With regard to SOFTBANK rebates, tell us whether measurement of
the rebates is based upon a targeted cumulative level of revenue,
the
nature of the targets, how the rebates are calculated, whether
such
targets are subject to adjustment based on competitive conditions
and
the frequency with which such changes are made. If targets are
subject to adjustment, tell us how you are able to make reasonable
estimates.  Refer to Issue 6 of EITF 01-9.

Note 1 - Significant Accounting Policies

Revenue recognition, page F-12

Prior Comment Number 2

3. We note in your response that "buyers are obligated to inspect
the
delivered products for obvious and visible defects within
specified
days from the date of delivery [and that] the risk of loss is
deemed
to be transferred to the buyer when inspected under the contract."
Tell us more about the "inspection" provisions contained in your
contracts. Address the following points in your response:
* Do all contracts with intermediaries have the same inspection
terms?  Tell us what those terms are in detail.
* Clarify what you mean by "within specified days." In this
regard,
tell us how long the typical inspection period lasts and clarify
when, and by what mechanism, title and risk of loss transfer to
the
customer. For example, is an affirmative acceptance from the
customer
required or do the acceptance provisions lapse by the passage of
time, in the absence of a rejection of the delivery by the
customer?
* Your filing indicates that you recognize revenue from sales to
intermediaries upon delivery.  Given the apparent lag between
delivery and title transfer, tell us how your revenue recognition
policy complies with the Interpretative Responses in SAB Topics
13.A
(3)(a) and 13.A (3)(b) Question 2.

4. With regard to your sales to SOFTBANK, describe any return
privileges, price protection or stock rotation rights offered to
this
distributor.  Tell us whether there have historically been changes
made to these policies, the frequency of such changes and how such
changes have impacted your ability to make reasonable estimates of
sales returns from this customer.

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

Prior Comment Number 4

5. We note that you intend to revise future filings to reclassify
maintenance and customer support costs as cost of sales.  Please
quantify the impact of these proposed reclassifications, including
your consideration of materiality under SAB 99, for each period
presented and tell us why you believe that prospective revisions
are
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.  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.

	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

Mahendra Negi
Trend Micro Incorporated
December 29, 2005
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