Via Facsimile and U.S. Mail
Mail Stop 6010


October 27, 2005


Mr. Jason A. Napolitano
Executive Vice President and
Chief Financial Officer
Heska Corporation
1613 Prospect Parkway
Fort Collins, CO 80525

Re:	Heska Corporation
	Form 10-K for Fiscal Year Ended December 31, 2004

	File No. 000-22427

Dear Mr. Napolitano:

       We have reviewed your October 14, 2005 response to our
letter
dated August 29, 2005 and have the following comments. We have
limited our review of your filing to those issues we have
addressed
in our comments. In our comments, we ask you to provide us with
information so we may better understand your disclosure.  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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment 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 10-K for the year ended December 31, 2004

Liquidity, Capital Resources and Financial Condition

Contractual Obligations, page 24
1. Please refer to our comment number 2 and your response.  We
note
in the last paragraph on page 30 that some of your license
agreements
impose milestone obligations on you.  Please address whether or
not
additional disclosure is necessary in the contractual obligations
table or in the footnotes to the table.



Consolidated Financial Statements

Notes to Consolidated Financial Statements

Note 2. Summary of Significant Accounting Policies

Goodwill and Other Intangible Assets, page F-47
2. Refer to your response to comment 3.  Unless it is probable
that
you will win the patent litigation, we believe legal costs to
defend
a patent should be expensed as incurred.  If you believe it is
probable that you will receive a favorable outcome, tell us why,
and
explain to us your accounting treatment for any expected proceeds
from the litigation.


*    *    *    *


      Please respond to the comments within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your responses to our comments and provides requested
information.  Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.



      You may contact Joseph Roesler, Staff Accountant, at (202)
551-
3628 or Mary Mast, Senior Accountant, at (202) 551-3613 if you
have
questions regarding the comments. In this regard, do not hesitate
to
contact me, at (202) 551-3679.

								Sincerely,


								Jim B. Rosenberg
								Senior Assistant Chief
Accountant
??

??

??

??

Jason A. Napolitano
Heska Corporation
Page 1