Mail Stop 6010

      December 19, 2005



VIA U.S. MAIL AND FAX (650) 567-5152

Mr. Kevin C. Eichler
Vice President and Chief Financial Officer
MIPS Technologies, Inc.
1225 Charleston Road
Mountain View, California 94043

	Re:	MIPS Technologies, Inc.
		Form 10-K for the year ended June 30, 2005
		Filed September 9, 2005
		File No. 000-24487


Dear Mr. Eichler:

      We have reviewed your response dated November 5, 2005 and
have
the following comment.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents. In our comment, we asked you to provide
us
with supplemental 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 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 June 30, 2005

Consolidated Financial Statements

Note 2. Summary of Significant Accounting Policies, page 36

Revenue Recognition, page 36

1. Please refer to our prior comment 1. We see that you allocate
the
total fee relating to multiple units of accounting to the
individual
units using the residual method.  Please tell us and revise future
filings to disclose why you use the residual method rather than
the
relative fair value method. We refer you to paragraph 12 of EITF
00-
21.


      As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your response to our
comment
and provides any requested supplemental information.  Detailed
cover
letters greatly facilitate our review.  Please file your cover
letter
on EDGAR as correspondence.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

      You may contact Julie Sherman, Staff Accountant, at (202)
551-
3640 or me at (202) 551-3603 if you have any questions regarding
these comments.  In this regard, do not hesitate to contact Angela
Crane, Accounting Branch Chief, at (202) 551-3554.



								Sincerely,



								Jay Webb
								Reviewing Accountant

Mr. Kevin Eichler
MIPS Technologies, Inc.
December 19, 2005
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