August 13, 2004



Mail Stop  0306

Pat V. Costa
Robotic Vision Systems, Inc.
486 Amherst Street
Nashua, New Hampshire 03063

Re:	Registration Statement on Form S-1
	Filed  August 6, 2004
	File No. 333-118017

Dear Mr. Costa:

	This is to advise you that we have reviewed only those
portions
of the above registration statement that relate to the plan of
distribution and have the following comment.

Plan of Distribution

	We note you registered 426,157 you intend to sell for your
own
account "pursuant to contractual commitments."  Since you already
made the offer prior to filing this registration statement you may
not register these securities for a primary offering.  Please
amend
the registration statement to remove these shares.  You may then
file
a new  registration statement for these securities after the sale
is
completed privately.

	No further review of the registration statement has been or
will
be made.  All persons who are by statute responsible for the
adequacy
and accuracy of the registration statement are urged to be certain
that all information required under the Securities Act of 1933 has
been included.

	You are also reminded to consider applicable requirements
regarding distribution of the preliminary prospectus.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert this action as 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 connection with our review of
your
filing or in response to our comments on your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

	If you have any questions, please call Alan Morris at (202)
942-
1980.

							Sincerely,



							David Ritenour
							Special Counsel


CC. Ira Roxland
Via FAX  212-768-6800