March 21, 2005


VIA USMAIL and FAX (604) 609-0611
Mail Stop 0409

Mr. Steven Vestergaard
Chief Executive Officer and Chief Financial Officer
Destiny Media Technologies Inc.
1055 West Hastings Street, Suite 1040

Re:	Destiny Media Technologies Inc.
      Form 10-KSB for the year ended 8/31/2004
      File No. 000-28259

Dear Mr. Vestergaard:

      We have reviewed your response letter dated February 24,
2005
and have the following additional comments.  These comments should
be
addressed in all future filings with the Commission, if indicated.
Supplementally provide to us the information requested if
indicated
and please be as detailed as necessary in your explanation.

FORM 10-KSB FOR THE YEAR ENDED AUGUST 31, 2004

Financial Statements and Notes

Note 3 - Significant Accounting Policies

Revenue Recognition, page F-8

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.

*  *  *  *

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

	You may contact Wilson K. Lee, at (202) 824-5535 or me, at
(202)
942-2814 if you have questions.



						Sincerely,



Kathleen Collins
Accounting Branch Chief






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Destiny Media Technologies Inc.
March 21, 2005
Page 1