April 17, 2006

Mail Stop 6010



James R. Oyler
President and Chief Executive Officer
Evans & Sutherland Computer Corporation
600 Komas Drive
Salt Lake City, Utah 84108

      Re:	Evans & Sutherland Computer Corporation
		Preliminary Proxy Statement on Schedule 14A
      Filed April 5, 2006
		File No. 001-14677

Dear Mr. Oyler:

      This is to advise you that we have monitored selected issues
in
the above-captioned proxy statement 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 us at the telephone numbers
listed
at the end of this letter

Schedule 14A

1. We note that Houlihan Lokey Howard & Zukin Financial Advisors
has
limited the use and benefit of its fairness opinion only to the
board
of directors.  Please note that shareholders are entitled to rely
on
the opinion expressed.  Please delete any portion of the fairness
opinion that disclaims responsibility to shareholders or implies
that
shareholders are not entitled to rely on the opinion.  Refer to
section II.D.1 of the Division`s November 2000 Current Issues
Outline.

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

	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 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 contact Eduardo Aleman at (202) 551-3646, or me at
(202)
551-3800 with any questions.

							Sincerely,



							Peggy Fisher
							Assistant Director


cc (via facsimile):  Troy Vigil
James R. Oyler
Evans & Sutherland Computer Corporation
April 17, 2006
Page 1