Mail Stop 4561
      June 1, 2005

Mr. Robert D. Selvi
Chief Financial Officer
SonicWALL, Inc.
1143 Borregas Avenue
Sunnvale, CA 94089

	RE:	SonicWALL, Inc.
		Form 8-K
		Filed May 25, 2005
            	File No. 0-27723

Dear Mr. Selvi:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document 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
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 comments or on any other
aspect
of our review.  Feel free to call me at the telephone number
listed
at the end of this letter.

Form 8-K filed May 25, 2005

1. Revise to provide the information required by Item
304(a)(1)(iv)(C) of Regulation S-K in regards to the disagreement
and
the material weaknesses.

2. Please provide us with a schedule of your quarter end
adjustments
for the material weaknesses identified in your Form 8-K for the
revised quarters ended March 31, June 30 and September 30.  Also,
provide a similar schedule for any 2004 fourth quarter audit
adjustments.  Clearly explain the reason for each adjustment.  For
each adjustment, show us the impact on pre-tax net loss.  Quantify
the net effect of all

adjustments on pre-tax net loss.  Also, tell us why none of the
adjustments relate to prior periods.  Explain in detail why you
believe the timing of each adjustment is appropriate.

3. Provide us with any letter or written communication to and from
the former accountants regarding any disagreements or reportable
events to management or the Audit Committee.

4. When you engage a new accountant, please report the engagement
in
a new Form 8-K and comply with the requirements of Regulation S-K
Item 304 (a)(2).  In making any disclosures about consultations
with
your new accountants, please ensure you disclose any consultations
up
through the date of engagement.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain 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 filing;

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



Please provide the supplemental information requested above within
five business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.

      Any questions regarding the above should be directed to me
at
(202) 551-3469.


								Sincerely,



								Thomas Flinn
								Staff Accountant
Mr. Robert Selvi
SonicWALL, Inc.
June 1, 2005
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