SecProbe.io

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Mail Stop 3561

      							July 14, 2005

David L. Adams
Sr. Vice-President, Finance and Chief Financial Officer
8150 Trans Canada Highway
Montreal, QC H4S1M5
Canada

	Re:	SR Telecom, Inc
      Form 20-F for Fiscal Year Ended December 31, 2004
		Filed May 2, 2005

		Forms 6-K for Fiscal Quarter Ended March 31, 2005
      File No. 000-50378

Dear Mr. Adams:

      We have reviewed your filing and have the following
comments.
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 documents.  Where indicated, we think you should
revise your documents in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may or may not
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 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 20-F for the fiscal year ended December 31, 2004

Item 4.  Information on the Company

History and Development of the Company, page 12

1. We note your disclosure that "SR Telecom USA Inc was primarily
an
R&D center, developing and maintaining both the angel and airstar
product lines".  Tell us if Netro conducted research and
development
activities prior to your acquisition and how such in-process
research
and development costs were accounted for in your purchase
accounting.
Further, your discussion should demonstrate the differences in
accounting treatment under US and Canadian GAAP, if any and site
all
relevant accounting literature.

Consolidated balance sheets, page F-2

2. We note your significant increase in inventory from December
31,
2003 and your explanation for this increase on page 36.

* Describe in detail why you believe your reserve for obsolescence
is
appropriate in light of your declining sales, lower backlog, and
delays in the receipt of orders, which have continued through
March
30, 2005.
* Tell us the nature of the inventory purchased from Solectron,
how
it will be utilized in your business, and why you believe the
inventory`s cost is less than or equal to market.

7. Long-term accounts receivable, net, page F-16

3. We note that you did not record a provision for your December
2001
claim filed against MCI International.  It is unclear to us why
you
believe this amount is recoverable at December 31, 2004
considering
MCI`s bankruptcy and subsequent objection to your claim.  Tell us
in
detail why you believe the claim will be upheld by the court and
further, why you believe you will receive full payment from MCI
International.

23. Loss on change in ownership in subsidiary company, page F-32

4. Tell us in more detail how an increase in the direct and
indirect
ownership in CTR resulted in an estimated charge to earnings under
U.S. GAAP.

24. Commitments and contingencies

d) Litigations, page F-33

5. We note that you recognized a gain of $4.6 million in
connection
with your settlement with Solectron.  Provide us with details of
your
prior accounting for your Manufacturing Agreement, and why the
subsequent recognition of a gain was appropriate.  Your response
should include a discussion of Canadian GAAP and U.S. GAAP,
highlighting any differences.

32.  Reconciliation of results reported in accordance with
Canadian
GAAP to U.S. GAAP and other supplementary U.S. GAAP disclosures,
page
F-41

6. Revise to provide the financial information for the year ended
December 31, 2002 as required by Item 18 of Form 20-F.

(i) Asset impairment, page F-42

7. Describe in detail the factors that contributed to the
adjustment
for asset impairment during each of the years presented.

(ii) Bid costs, deferred charges and start-up costs, page F-42

8. It appears from your disclosure that all deferred charges are
expensed as incurred under U.S. GAAP.  Tell us the nature of the
deferred charges that are expensed.  Disclose whether deferred
costs
incurred to issue debentures or debt are expensed or deferred
under
U.S. GAAP.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please file your response via EDGAR.  You may
wish
to provide us with marked copies of the amendment to expedite our
review.  Please furnish a cover letter with your 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 your amendment and 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      You may contact Nicole Holden, Staff Accountant, at (202)
551-
3374 or Kyle Moffatt, Accountant Branch Chief, at (202) 551-3836
if
you have questions regarding comments on the financial statements
and
related matters.  Please contact me at (202) 551-3810 with any
other
questions.

								Sincerely,

								Larry Spirgel
								Assistant Director

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Mr. Adams
SR Telecom,Inc
July 14, 2005
Page 4

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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