SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

<TABLE>
<CAPTION>

Destiny Media Technologies

1040-1055 W. Hastings St.
Vancouver, BC CANADA V6E 2E9
(t) 604.609.7736
(f) 604.609.0611
www.dsny.com

<S> <C>
</TABLE>

April 5, 2005

Kathleen Collins
Accounting Branch Chief
Division of Corporate Finance
United States Security and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. USA
20549

Dear Ms Collins:

RE:    DESTINY MEDIA TECHNOLOGIES INC.
       FORM 10-KSB FOR THE YEAR ENDED AUGUST 31, 2004
       FILE NO. 000-28259

We  are  writing  in  response to  your letter dated March 21, 2005  requesting
additional information pursuant  to our annual Form 10-KSB for the year  ending
August 31, 2004.

We provide our comments below.

   1.  We  note  from  your  response  to  our previous comment no. 1 where you
       indicate that development fees are billed  separately and in addition to
       the  license  fee  as  established  in  your price  list.   Pursuant  to
       paragraph  74  of  SOP  97-2  if  the  software   requires   significant
       customization, the service element (development fee) does not  meet  the
       criteria  for  separate  accounting.  Based on your response, it appears
       that the Company accounts for the license  fee  and  the development fee
       separately.   Please  explain  and tell us how your accounting  complies
       with SOP 97-2.

       Occasionally, a customer will request  a  customization  to  one  of our
       Clipstream  {TM}  suite  of  products.   Examples  include  changing the
       user    interface,    adding    minor   functionality   or   integrating
       Clipstream {TM}  into  their   environment.    These  modifications  are
       minor and usually are isolated to the particular customer.

       Our  development  fee  revenue was less  than  7%  of  total  Clipstream
       {TM}   revenue  for   fiscal   2004.   Revenue   associated   with   the
       customization  is  recognized  upon  completion  and  acceptance  of the
       development  work.    Revenue  associated with the license is recognized
       upon delivery of the relevant code key to utilize the license.

       It  is  our  view that the modifications  don't  materially  change  the
       product (license)  delivered.  Nevertheless, these two revenue items are
       generally  delivered  (and  therefore   recognized   into   revenue)  at
       approximately the same time.

                                   * * * * *

Yours truly,

Steve Vestergaard,
Chief Executive Officer
Destiny Media Technologies

 Destiny Media Technologies * 1040-1055 West Hastings St. * Vancouver, B.C. *
                                    V6E 2E9
             (t) 604.609.7736 *  (f) 604.609.0611 * www.dsny.com

</TEXT>
</DOCUMENT>